WATSON
v.
STATE OF FLORIDA
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Watson appeals the trial court's denial of his motion to exclude Williams Rule evidence (similar fact evidence). The appellate court found the trial court abused its discretion by admitting evidence of a 2012 offense that was not sufficiently unique to constitute "fingerprint" evidence and whose probative value was substantially outweighed by unfair prejudice.
The trial court abused its discretion in allowing the evidence. Similar fact evidence must demonstrate striking similarity with identifiable points so unusual as to constitute "fingerprint" evidence. The 2012 incident evidence did not meet this standard and its probative value was substantially outweighed by the danger of unfair prejudice.
[1] Similar fact evidence is admissible only when the facts of the offenses are strikingly similar and possess unique characteristics that serve as "fingerprint" evidence poi…
[2] The probative value of similar fact evidence must not be substantially outweighed by the danger of unfair prejudice.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“For similar fact evidence to be admissible, the facts of the offenses must be strikingly similar and "[t]here must be identifiable points of similarity which pervade the compared situations . . . [T]he points of similarity must have some special character or be so unusual as to point to the defendant."”
Establishes the legal standard for admissibility of similar fact evidence under Florida law, citing Drake v. State.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceWatson was charged with loitering and prowling and indecent exposure. The State sought to introduce evidence of a similar 2012 offense as knowledge ev…
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Before TRAVER, HIGBEE, EGAN, J.J.
PER CURIAM.
Jermetras Watson (“Appellant”) appeals the denial of his “Motion to Exclude Williams Rule Evidence” (“Motion to Exclude”). This court has jurisdiction pursuant to Florida Rule of Appellate Procedure 9.030(c)(1).
Appellant argues that the court erred in denying his Motion to Exclude, and allowing the State to present similar fact evidence of a 2012 offense. The Court finds that the denial of the Motion to Exclude was an abuse of discretion. The State sought to introduce similar fact evidence solely as knowledge of Defendant’s loitering and prowling count. It also indicated that it would introduce similar fact evidence as to absence of mistake on the exposure count, but only if Defendant testified. (Hearing Transcript at 19-20). The Defendant did not testify, and absence of mistake never became relevant. Nevertheless, the Court allowed evidence of the 2012 incident as to both exposure and loitering and prowling allegations at trial. (Trial Transcript at 281).
For similar fact evidence to be admissible, the facts of the offenses must be strikingly similar and “[t]here must be identifiable points of similarity which pervade the compared situations . . . [T]he points of similarity must have some special character or be so unusual as to point to the defendant.” Drake v. State, 400 So. 2d 1217, 1219 (Fla. 1981). The characteristics of the crimes must be so unique as to constitute “fingerprint” evidence. State v. Savino, 567 So. 2d 892, 894 (Fla. 1990).
In the instant case, the evidence presented was not so unique as to constitute “fingerprint” evidence, and was typical of any perpetrator engaging in public masturbation. See Kulling v. State, 828 So. 2d 311 (Fla. 2d DCA 2002). The probative value of the similar fact evidence was substantially outweighed by the danger of unfair prejudice. See § 90.403, Fla. Stat. (2015).
Based on the foregoing, it is hereby ORDERED AND ADJUDGED that the Final Judgment and Sentence is REVERSED and the matter REMANDED for a new trial.
DONE AND ORDERED in Chambers, at Orlando, Orange County, Florida, on this 8 day of March, 2017.
/S/
DAN TRAVER
Presiding Circuit Judge
HIGBEE and EGAN, J.J., concur. Certificate of Service
I HEREBY CERTIFY that a copy of the foregoing Final Order Affirming in Part and Reversing in Part Trial Court has been provided to Manuel Soto Diaz, Assistant Public Defender, to Daniel J. Quinn, Assistant State Attorney, 415 North Orange Avenue, Orlando, Florida 32801, and to The Honorable Faye L. Allen, 425 North Orange Avenue, Orlando, FL 32801 this 8th day of March, 2017.
/S/
Judicial Assistant
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Citator
Authorities Cited
- Drake v. State, 400 So. 2d 1217 (Fla. 1981)
- State v. Savino, 567 So. 2d 892 (Fla. 1990)