## Facts

- Derrick Dotson was indicted in Louisiana for aggravated rape and was tried and convicted.
- During voir dire, prospective juror K.C. disclosed that her mother had been raped and murdered.
- When questioned, K.C. indicated that what happened to her mother might affect her ability to be fair and impartial in Dotson’s case.
- Defense counsel did not ask K.C. follow-up questions to clarify or test her ability to set aside that experience.
- The defense challenged K.C. for cause based on her responses.
- The trial judge denied the challenge, stating that the fact K.C.’s mother had been raped and murdered was not, by itself, cause to excuse her.
- As defense counsel began to argue that K.C. “said that would—,” the judge interrupted, stating, “No, she didn’t.”
- On appeal, the Louisiana court of appeal reversed Dotson’s conviction, concluding that bias or inability to decide the case based on the law could be reasonably implied from K.C.’s response and that the trial court abused its discretion by denying the cause challenge.
- The State sought review in the Louisiana Supreme Court.

## Issues

1. Did the trial court abuse its broad discretion by denying the defense challenge for cause to a prospective juror who disclosed a close family history of rape and murder and gave an equivocal response about impartiality?

## Decision

- The Louisiana Supreme Court reversed the court of appeal.
- The Court held the trial judge did not abuse his discretion in denying the defense challenge for cause.
- The Court reinstated Dotson’s aggravated-rape conviction.

## Legal Principles

- A trial court has broad discretion when ruling on challenges for cause, and an appellate court reverses only when the full voir dire record shows an abuse of that discretion.
- Juror qualification must be evaluated from the entire voir dire, not from isolated answers or a single equivocal remark.
- A prospective juror who initially expresses doubt or discomfort may still be found qualified when later responses show an ability to follow the law and decide the case fairly.
- Because the trial judge observes the venire member’s manner of answering (including tone and demeanor), reviewing courts generally defer to the judge’s assessment unless the record clearly shows the juror could not be impartial.

## Conclusion

In *State v. Dotson*, the Louisiana Supreme Court concluded that the court of appeal erred by overturning Dotson’s aggravated-rape conviction based on the denial of a cause challenge. Reviewing the voir dire as a whole and giving deference to the trial judge’s ability to assess the juror in real time, the Court found no abuse of discretion in refusing to excuse K.C. for cause and reinstated the conviction.


State v. Dotson, 234 So. 3d 34, 2017 WL 4681942 (2017)