State v. L.C.
Matthew B. Nichols
120 years in prison
Arson (3 counts)
Time Lines to Prove Not Guilty
Client was suspected of setting five fires at St. Joe’s Hall on the campus os St. Joseph’s College. The first fire was set on Friday, March 31, 2000 in the early afternoon. One more was set on April 1, 2000. Yet another was set early on April 2, 2000 and 3:00 a.m. April 3, 2000. The Sunday night fire was set in the bathroom across from her room. The Monday morning fire was set in her room and caused over $300,000.00 in property damage.
The State’s case was based on the following:
- Client’s alleged involvement in the three uncharged arsons (through a Motion in Limine, the defense had these excluded. The prior “bad acts” were not sufficiently linked to her to allow them into evidence).
- Client’s alleged motive to set and discover fires to reverse a decision to not re-hire her as a Residential Advisor (our investigator discovered that a key State’s witness on motive did re-hire client by verbal commitment on the morning of March 31, 2000; the State found this out on our cross-examination of their key motive witness).
- Client’s error in time references during police interrogation after the big fire (the time reference errors were readily accounted for because she was looking at clocks that had not “sprung forward” for daylight savings time).
Client’s “relative” times were accurate (45 minutes from the time she left her room to the time of the fire alarm). The state never understood that her room clock was still an hour behind as was the clock in the administration office in which she was interrogated. Thus, the State thought she had a full hour of unaccounted for time without any alibi.
The plausibility of her mistake was apparent to all Jurors at the outset of our opening statement (on Monday morning at 9:30 a.m.) when we pointed to the court clock which read . . . 10:30 a.m. The corrected time, coupled with testimony from that State’s witnesses showed that Client had neither the motive, nor the opportunity to set the Monday morning fire. Time line evidence (T.V listing, alarm records, phone records etc.) also showed that Client had neither motive, nor the opportunity to set the Sunday night fire.