Lee v. Georgia
Annotate this CaseIn January, 2008, the State filed accusations against Appellant Hwa Ja Lee, charging her with three misdemeanor offenses: pimping, prostitution and keeping a house of prostitution. Appellant raised the state statute of limitations as her defense, which required the state to commence proceedings within two years of the filing of the accusation. The trial court found that the statute had not run, and barred Appellant from raising the statute of limitations as a defense to the jury. However, in it its charge to the jury, the trial court included suggested pattern instructions on the statute of limitations. The jury found Appellant guilty on all accusations; the Court of Appeals reversed the pimping conviction because it found the statute had run. The Supreme Court, on review of the courts below, found that the jury was not authorized to find that crimes took place within the applicable statute of limitations, and that the trial court was not authorized to prohibit the Appellant from raising the dates of the accusations in her defense. The Court affirmed the Appellate court on the pimping, but reversed on the house of prostitution accusations.
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