Robert Paul Bolton was a 28-year-old White/Caucasian male and an officer with the Eau Claire Police Department when he was killed in the line of duty during the early morning hours of October 6, 1982. Bolton had served with the department for approximately four years and carried badge number 138. What began as a response to a domestic violence disturbance at a local shelter ended with Bolton being fatally shot while attempting to deal with the man involved in the incident.
The shelter
was then known as Refuge House and provided protection for people fleeing domestic abuse. Bolton was dispatched there after trouble developed involving an alleged abuser. After arriving, he attempted to question and stop the man. Historical accounts of the shelter describe the suspect as moving toward or attempting to leave in a vehicle when Bolton intervened. During the confrontation, Bolton was shot. He was rushed to a local hospital, but his wounds proved fatal.
Authorities identified Christian R. Bangert as the man responsible for Bolton's shooting. Bangert was arrested and initially charged with first-degree murder in connection with Bolton's death. Prosecutors subsequently filed an additional charge of endangering safety by conduct regardless of life. The prosecution of Bangert became a significant criminal case in Eau Claire County and later produced a Wisconsin Supreme Court decision concerning the procedures courts must follow when accepting guilty or no-contest pleas.
Bangert initially sought to have his trial moved out of Eau Claire County because of concerns surrounding publicity. In December 1982, the court granted his request and moved the case to Douglas County. Several months later, prosecutors asked that the proceedings be returned to Eau Claire County, in part because conducting the trial elsewhere would create staffing difficulties for the Eau Claire Police Department. A plan was eventually developed to select a jury in Douglas County and bring the jurors to Eau Claire for the trial.
A jury trial never took place. On May 25, 1983, Bangert entered a no-contest plea to a reduced charge of second-degree murder as part of a plea agreement with prosecutors. In exchange for the plea, the separate endangering-safety charge was dismissed. The agreement also contained provisions governing the prosecution's sentencing recommendation and its position regarding future parole requests. By accepting the plea, the court resolved the murder prosecution without requiring witnesses and evidence to be presented to a jury.
On July 13, 1983, the court sentenced Bangert to the maximum twenty-year prison term available for the second-degree murder charge under the law then applicable to the case. Bangert later attempted to withdraw his no-contest plea, arguing in part that the original plea hearing had not adequately established that he understood the nature of the charge and the constitutional rights he was giving up. His post-conviction challenge eventually reached the Wisconsin Supreme Court.
In 1986, the Wisconsin Supreme Court acknowledged that the original plea questioning conducted by the trial judge had been inadequate, particularly because the judge had not sufficiently explained the elements of second-degree murder or personally established Bangert's understanding of the constitutional rights he was surrendering. However, after examining the larger record, including evidence from a later post-conviction hearing, the court concluded that Bangert had nevertheless entered the plea knowingly, voluntarily, and intelligently. The court also rejected his claim that alleged violations of the plea agreement entitled him to withdraw the plea. His second-degree murder conviction and sentence therefore remained in place.
Bolton's death had a lasting effect on both the Eau Claire Police Department and the domestic violence organization where the shooting occurred. Refuge House was later renamed Bolton Refuge House in his honor and continues to commemorate his sacrifice. The Eau Claire Police Department permanently retired badge number 138, and Bolton remains remembered as an officer who was killed while responding to protect people during a domestic violence emergency.
