Ryan v. State

Roy Ryan (defendant) was married to Keri Ryan. Their marriage was turbulent, and domestic violence was prevalent, as witnessed by numerous friends, neighbors, and coworkers. Ryan routinely kicked and punched Keri, isolated and controlled her, and demanded to know where she was. Keri’s coworkers noted that Ryan called Keri incessantly at work, 10 times or more during a shift, to check on her. Ryan emotionally abused Keri through constant criticism. Ryan was also excessively jealous, often accusing her of having extramarital affairs. In early November 1996, the couple separated. Keri obtained a restraining order against Ryan but later had it dismissed. Thereafter, Keri began dating someone else. Ryan became depressed and lost noticeable weight. One evening, Ryan shot Keri with a gun and then shot himself. Ryan called 911 as he was bleeding out in the home where Keri was dying or already dead. The state (plaintiff) charged Ryan with murder. At trial, numerous witnesses testified to Ryan’s abusive conduct, which he admitted. The state also introduced the testimony of an expert witness, Rosemary Bratton, who had worked with both battered and battering spouses. Bratton not only testified about battered-woman syndrome to explain Keri’s conduct, but also testified about the characteristics and common behaviors of an abusive spouse. For example, Bratton described batterers’ tactics to control and isolate, threats to commit suicide, and tendency toward pathological jealousy, including incessant calls and accusations. Bratton further testified to increased violence during a couple’s separation period due to the abuser’s growing anger and anxiety and that abusers were more likely to commit acts of violence with guns during the period. The jury convicted Ryan, and he appealed, arguing that Bratton’s testimony was erroneously admitted as character evidence against him.