State v. Freeman

Samuel Freeman (defendant) was tried for first-degree murder. Witnesses testified at trial that Freeman and the female victim were regular patrons of the same bar. On the night of the murder, Freeman and the victim had an argument over the use of the bar’s pool table. The victim also rebuffed Freeman’s attempt to flirt with her. Witnesses saw Freeman leave the bar with an empty Galliano liqueur bottle, given to him by a waitress. The prosecution introduced Galliano bottles as demonstrative evidence during testimony about Freeman’s actions at the bar. The bottles had a distinctive shape unknown to the average person. The victim left the bar 15 minutes after Freeman and drove to her apartment, which was a quarter of a mile away. The victim’s neighbor saw the victim arrive home. The neighbor saw a man approach and enter the victim’s apartment with her. The victim’s body was found in her apartment the next day. The victim was undressed, had been struck in the head with a smooth object, had been sexually assaulted with a foreign object, and had been asphyxiated with her own stocking. The jury found Freeman guilty of the murder. Freeman appealed, arguing that the introduction of the Galliano bottles was improper because it was irrelevant and inflamed the jury by imparting the idea that the victim’s sexual assault was performed with the Galliano bottle.