Bartlett v. State

Laurie Lynn Bartlett (defendant) stabbed her ex-boyfriend, Ernest Lamar, to death. The State of Florida (plaintiff) charged Bartlett with second-degree murder. Bartlett claimed that she acted in self-defense based on battered-spouse syndrome. At trial, the state introduced Investigator Mark Walton, who had investigated the scene. Walton testified that he had ruled out self-defense. The state asked Walton to explain his reasoning. The defense counsel objected on the ground that Walton’s answer would improperly rely on opinion and speculation. The objection was sustained. The state argued that Florida’s new self-defense law requires that the investigator determine whether self-defense should be ruled out before signing a complaint and that the court should allow the investigator to testify about how he made such a determination. The trial court then overruled the objection and allowed Walton to testify about the facts that he relied on to make his determination. Walton testified that Bartlett’s story was inconsistent with the evidence and that the force and angle of the knife made self-defense unlikely. Walton began describing other incidents of self-defense he had observed. The defense counsel objected on relevancy grounds. The objection was overruled. When Walton began speaking about statements that witnesses had made, the defense counsel objected on hearsay grounds. The state ended the direct examination. Following the cross-examination, the jury found Bartlett guilty of manslaughter, a lesser offense. The conviction was appealed on the ground that the court erred in admitting Walton’s testimony.