BRAMLETT v. STATE
422 P.3d 788
Okla. Crim. App.2018Background
- Victim Michelle Spence was found dead by her sons in her SUV on March 20, 2015; cause of death was asphyxia by strangulation.
- Evidence tying Renese Bramlett to the scene: surveillance video, cell‑phone location records, and witness observations; Bramlett left for Chicago the day after discovering Spence missing and was later located there.
- Bramlett was detained in Chicago on a material‑witness warrant, interviewed by Tulsa detectives (videotaped), then charged with first‑degree murder; he waived extradition and was returned to Oklahoma for trial.
- Bramlett conceded voluntariness of his statements but argued his interview was the product of an illegal arrest/detention and thus should be suppressed.
- The State introduced prior‑bad‑act evidence that Bramlett had previously beaten/strangled Spence (2013); the trial court admitted it under 12 O.S. § 2404(B) with limiting instructions.
- After conviction (jury found guilt; jury imposed life without parole), Bramlett appealed raising multiple issues; the Court affirmed conviction but vacated sentence and remanded for resentencing due to prosecutorial misstatements about parole eligibility.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Bramlett's custodial statement (suppression) | Bramlett: arrest/detention on a material‑witness warrant in Chicago was illegal; statement is fruit of poisonous tree | State: propriety of removal under extradition/uniform witness act not controlling for voluntariness of pre‑removal interview; record lacks warrant to review | Court: No reversible error — defendant failed to include warrant and supporting docs in record; trial court not shown to have abused discretion; no relief |
| Admission of videotaped interview showing jail clothes/handcuffs | Bramlett: video prejudicial; appearance in restraints/jumpsuit should be excluded under Deck and due process | State: video probative of demeanor and voluntariness; jurors expect detainees to be restrained; less prejudice than courtroom shackling | Court: No abuse of discretion — probative value outweighed prejudice; Deck not extended to pretrial jail videotape |
| Admission of prior bad act (2013 assault/strangulation) | Bramlett: evidence inadmissible character evidence; not within § 2404(B) exceptions | State: prior strangulation shows motive, intent, identity; clear connection and clear/convincing evidence; limiting instructions given | Court: Admissible under § 2404(B); probative value outweighed prejudice; no abuse of discretion |
| Hearsay / Confrontation regarding testimony about prior relationship | Bramlett: sister's testimony about who was victim's boyfriend was hearsay/testimonial | State: sister's testimony based on personal observation and was subject to cross‑examination | Court: No hearsay or Crawford violation shown; testimony admissible; no plain error |
| Discovery / Brady (prosecutor decline sheet) | Bramlett: DA file may contain exculpatory decline sheet; requested in camera review; failure violated discovery/Brady | State: decline sheet is work product; police report (naming Bramlett) was provided; no showing of suppressed materiality | Court: No Brady violation shown; in camera review not required; no plain error |
| Lay vs expert testimony (cell‑phone / geo‑location) | Bramlett: Corporal Schilling’s testimony was expert; trial court failed Daubert gatekeeping | State: testimony was lay opinion based on perception/training and admissible under § 2701; Daubert limited to novel scientific evidence | Court: Defense either invited the ruling or waived objection; testimony was permissible lay opinion; no reversible error |
| Prosecutorial misconduct in sentencing argument (85% Rule misstatements) | Bramlett: prosecutor misstated parole law (presented 85% as automatic release) influencing jury's sentencing choice | State: conceded misstatement but argued harmless based on precedent | Court: Misstatements were actual/plain error, undermined fairness of sentencing phase; prosecutor’s repeated misstatements warranted vacatur of sentence and remand for resentencing |
Key Cases Cited
- Wong Sun v. United States, 371 U.S. 471 (illegal arrest fruit‑of‑poisonous‑tree/attenuation analysis)
- Miranda v. Arizona, 384 U.S. 436 (custodial‑interrogation warnings requirement)
- Deck v. Missouri, 544 U.S. 622 (visible restraints before a jury require specific justification)
- Crawford v. Washington, 541 U.S. 36 (Confrontation Clause bars testimonial hearsay without prior opportunity for cross‑examination)
- Brady v. Maryland, 373 U.S. 83 (prosecution must disclose materially exculpatory evidence)
- Daubert v. Merrell Dow Pharmaceuticals, 509 U.S. 579 (gatekeeping for scientific expert testimony)
- Florez v. State, 239 P.3d 156 (Okla. Crim. App. 2010) (condemning prosecutor misstatements about 85% Rule)
- Taylor v. State, 248 P.3d 362 (Okla. Crim. App. 2011) (caution re: misstating 85% Rule)