Court Testimony About the Color of Stains and Their Relationship to Blood
In Gantling v. State, 40 Fla. 237, 23 So. 857 (Fla. 1898), the court held that it was not improper for a witness to testify regarding the color of stains on a garment and their relationship to blood. Id. at 860.
Specifically, after the trial court sustained a defense objection to the witness's testimony "that he saw splotches or stains of some kind . . . , which he supposed was blood; he felt confident that it was blood," the witness rephrased his testimony, stating that he was not an expert and "that the stains were of a yellow or reddish color; they had been there so long that they were not the color of blood." Id.
The court held that such testimony was not improper and that the trial court properly overruled the objection to it, stating, "It requires no expert knowledge to enable one to know that there are stains upon clothing, nor their color, where they are visible to the eye.
These are matters open to common knowledge and common observation." Id.