Washington v. Lee (Majority and Concurrence)Annotate this Case
Limiting the scope of that cross-examination was within the court's discretion. Donald Lee was convicted on two counts of third degree rape of a child. The trial court permitted Lee to ask J.W. if she had made a false accusation to police about another person, but it prevented Lee from specifying that the prior accusation was a rape accusation. Lee claimed this violated his confrontation clause rights. Lee also contended the four year delay between his initial arrest and the trial was unconstitutional, warranting review for the first time on appeal. Lee also challenged the trial court's imposition of legal financial obligations (LFOs ). Because the State's legitimate interests in excluding prejudicial evidence and protecting sexual assault victims outweighed Lee's need to present evidence with minimal probative value, the trial court did not abuse its discretion when it prevented Lee from specifying that J.W. had falsely accused another person of rape. When the court permitted Lee to cross-examine J.W. about her prior false accusation, it provided Lee with an adequate opportunity for confrontation. Furthermore, because Lee was not actually restrained and because charges had not been filed, the four year delay between his initial arrest and the trial was not a manifest constitutional error warranting review for the first time on appeal.