An accused killer clown in Florida has been held in jail without bond since 2017 based on conflicting evidence

• In 1990, a person dressed as a clown knocked on Marlene Warren's door and shot her in the head before escaping in a white Chrysler LeBaron.
• In 2017, Shelia Keen-Warren was charged with the murder of Marlene Warren, but her defense team says the evidence is not nearly strong enough to support holding her in jail without bail for over three years.
• Her lawyers say three of the four witnesses of the crime told investigators that the clown was at least 6 feet tall and a man, but Keen-Warren is 5-foot-7 and is a woman.

A Florida woman accused of dressing as a clown in a 27-year-old cold-case homicide has been incarcerated without bond since 2017.

In a motion for bond filed on January 4, her lawyers are trying to get her released ahead of trial.

In 2017, Sheila Keen-Warren was charged with the 1990 murder of her husband's then-wife, Marlene Warren.

In May 1990, a person in a clown costume driving a white Chrysler LeBaron drove to the home of Michael and Marlene Warren in Wellington, Florida, according to the facts and procedural history section of Keen-Warren's motion for bond.

The clown knocked on the front door of the house, carrying two balloons and a flower arrangement. After Marlene Warren answered the door, the clown shot her in the head before walking to the Lebaron and leaving the scene.

"There is no reliable physical or testimonial evidence that she committed this crime, yet Ms. Keen-Warren has been incarcerated without a bond since October 4, 2017," Keen-Warren's lawyers submitted to the court. "Any continued restrictions on her liberty are both punitive and a violation of the presumption of innocence."

The shooting has been investigated by four different sets of detectives, but it was not until Detective Paige McCann took over the case in 2013 that the state had probable cause to charge Keen-Warren with the murder of Marlene Warren, the defense team says.

But in the four years that McCann investigated the case, the only additional evidence uncovered were microscopic hairs and an FBI analysis, according to the defense's court filings.

The defense is arguing the evidence against their client is scant, and she should at least be released ahead of trial

Keen-Warren's lawyers said the evidence the state presented to incarcerate their client is scant and unreliable.

"After a 27-year-investigation that turned up no credible evidence linking Sheila Keen-Warren to the murder of Marlene Warren," Keen-Warren's lawyers wrote, "the State determined that it had sufficient evidence to prosecute her on flimsy circumstantial evidence stacked on flimsy circumstantial evidence."

Four people witnessed the shooting: Warren's son, Joseph, and his three friends.

Directly after the incident, her lawyers said, three of the witnesses "unequivocally" told investigators that the clown was a tall man ranging from 6 feet to 6 feet 2 inches tall - the fourth witness could not tell if the clown was male or not, but confirmed the killer's height.

According to the defense, one of the witnesses also told investigators that "it was a man, it wasn't a woman."

But Keen-Warren is a 5-foot-7-inch woman.

Prosecutors said in their motion to admit evidence that the witnesses described the killer as having "man like features."

State prosecutors also said in court documents that at the time of the murder, Keen-Warren was a "taller, thin, white female with long brown hair and was described to have masculine features."

In their motion, the defense team continued to list the reasons why the evidence provided by the state is not enough to hold their client without bail.

Following the shooting, investigators went to Publix, a grocery store, and spoke with two employees who said a woman had purchased balloons and flowers similar to the flowers found at the scene. When Keen-Warren's photo was placed in a photo lineup for the employees to peruse, they could not identify Keen-Warren as the shopper, her lawyers said.

Two employees from a costume shop also reached out to investigators and said they sold a clown costume to a woman just two days prior to the homicide, according to the court docs. After being presented with a photo lineup that included Keen-Warren, neither employee could definitively point to Keen-Warren as the purchaser, the defense said.

According to the defense team, it was not until a year after the homicide had occurred that the employees were interviewed for a second and third time before admitting to discussing the case together and reading newspaper articles with Keen-Warren's photograph.

Following this, the defense team alleges, the two employees "suddenly expressed more confidence in their identifications."

In their search, investigators recovered several white Chrysler LeBarons that they believed might be the getaway car, one of which was linked to a grand theft committed 30 days prior to the shooting and had ties to Michael Warren.

According to the defense, the Palm Beach County Sheriff's Office recovered several fibers and hairs from the vehicle, but one witness to the crime repeatedly denied that the vehicle was the getaway car in question. After forensic evidence, the FBI found that the DNA from the skin on the root of a hair found in the car was mainly from a male person, the defense said.

Lastly, the defense says the state found orange/yellow acrylic hairs in the vehicle and that the FBI analyzed only "yellow modacrylic wig type fibers." According to the defense filing, after interviewing the three witnesses who described the clown as wearing a wig, zero of them said the wig was yellow - two witnesses said it was red and one said it was orange.

Sheila Keen-Warren and Michael Warren got married in 2002

When interviewed by investigators, Keen-Warren denied any romantic involvement between her and Michael Warren around the time of the murder. The two owned a restaurant in Tennessee, The Purple Cow, from 1993 to 2016, according to the court filings.

Twelve years after the homicide took place, the two got married. According to WJHL, the couple was living in Abingdon, Virginia, when Keen-Warren was extradited to Florida in 2017.

According to the Florida Rules of Criminal Procedure, all offenders except ones charged with a capital offense or an offense punishable by life in prison are "entitled to pretrial release on reasonable conditions." As Keen-Warren is being charged with homicide, she is not immediately eligible for a pretrial release.

In light of this, and due to the preponderance of conflicting evidence and the rising threat of COVID-19 in the US prison system, Keen-Warren's attorneys asked the court in their motion to set a $50,000 bond for Keen-Warren to be placed in Palm Beach Sheriff's Office in-house arrest if the court requests more restrictive conditions for her release.

The prosecuting team declined to comment, noting that it would not "make extrajudicial comments on an open case."