THE STATE OF FLORIDA, PETITIONER,
v.
KATRACY DAWSON, RESPONDENT
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The State of Florida sought certiorari to overturn trial court orders excluding Williams Rule evidence (evidence of other crimes) in two consolidated criminal cases against Katracy Dawson. The appellate court denied the State's petition, finding the trial court properly excluded the evidence as having limited probative value substantially outweighed by unfair prejudice risk.
The trial court did not abuse its discretion in excluding the Williams Rule evidence. Although the shell casing evidence may have been marginally relevant, its limited probative value was substantially outweighed by the danger of unfair prejudice, and the State had alternative means to prove identity.
[1] Williams Rule evidence is inadmissible when its limited probative value is substantially outweighed by the danger of unfair prejudice.
[2] Williams Rule evidence is not admissible to establish identity when the crimes are not inextricably intertwined.
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Join FLexlaw to unlock all legal intelligence“even if the [subject] Williams Rule evidence is marginally relevant, its limited probative value is substantially outweighed by the danger of unfair prejudice to the Defendant”
Trial court's rationale for excluding the evidence, which the appellate court affirmed as correct application of evidence law
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Join FLexlaw to unlock all legal intelligenceTwo crimes were committed involving nine-millimeter shell casings found at both scenes. In the first crime, the victim identified Dawson from a photog…
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SHEVIN, Judge.
In these consolidated cases, the State of Florida petitions for a writ of certiorari asking us to quash trial court orders denying the State’s motions to introduce Williams Rule evidence in two cases pending prosecution in the trial court. We deny the petitions.
In its well-reasoned order, the trial court correctly found that the proposed Williams Rule1 evidence was not relevant and admissible to establish the defendant’s identity as the perpetrator of the subject offenses. See Dixon v. State, 627 So. 2d 1337 (Fla. 2d DCA 1993). The sole evidence that is similar among the two crimes are the nine-millimeter shell casings found at the scenes. Based on that comparison, the police showed the victim of the first crime a picture of defendant, who was arrested at the scene of the second offense; and the victim identified the person in the picture as the perpetrator. As the trial court correctly found, “even if the subject Williams Rule evidence is marginally relevant, its limited probative value is substantially outweighed by the danger of unfair prejudice to the Defendant....”
The state’s argument that this information is crucial to its case overlooks the fact that in the first case, no doubt the victim will identify the perpetrator, and in the second case the police will identify the perpetrator as the person they ran over. Also, in the second case, the victim’s property was found on the perpetrator’s person. Hence, this Williams Rule evidence is not the sole means for the state to prove identity. Moreover, contrary to the state’s argument, Amoros v. State, 531 So. 2d 1256 (Fla.1988), does not require that we grant certiorari in this case. The two crimes at issue here are “not intertwined inextricably as they were in Amoros.” Dixon, 627 So. 2d at 1339.
In view of the foregoing, we cannot hold that the trial court abused its discretion in striking the Williams Rule notice. The state has not demonstrated that the trial court departed from the essential requirements of law in this case. See State v. Escobar, 570 So. 2d 1343 (Fla. 3d DCA 1990).
We find no merit in defendant’s objection to admission of evidence that he was in possession of the gun when he was arrested.
Certiorari denied.
. See Williams v. State, 110 So. 2d 654 (Fla.), cert. denied, 361 U.S. 847, 80 S.Ct. 102, 4 L.Ed.2d 86 (1959).
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Citator
Cited By
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State v. Williams, 992 So. 2d 330 (Fla. 3d DCA 2008)…air prejudice: whether the “probative value is substantially outweighed by the danger of unfair prejudice.” § 90.403, Fla. Stat. (2005) (emphasis added). In concluding that the evidence should be excluded, the trial court relied on State v. Dawson, 766 So. 2d 1109 (Fla. 3d DCA 2000). We find, however, that this ease is not applicable here. In Dawson, the defendant was accused of crimes committed in two incidents. Nine-millimeter shell casings were found at both crime scenes. The trial court ruled that even if…
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Katracy Dawson v. State, 121 So. 3d 63 (Fla. 3d DCA 2013)…533 (Fla. 3d DCA 2006); Dawson v. State, 861 So. 2d 38 (Fla. 3d DCA 2003); Dawson v. State, 848 So. 2d 325 (Fla. 3d DCA 2003); Dawson v. State, 825 So. 2d 1080 (Fla. 3d DCA 2002); Dawson v. State, 819 So. 2d 775 (Fla. 3d DCA 2002); State v. Dawson, 766 So. 2d 1109 (Fla. 3d DCA 2000); Dawson v. State, 743 So. 2d 522 (Fla. 3d DCA 1999). . Additionally, even if this claim were asserted pursuant to Florida Rule of Criminal Procedure 3.850, it is time barred. See Ponton, 971 So. 2d at 814.…
Authorities Cited
- Williams v. State, 110 So. 2d 654 (Fla. 1959)
- Williams v. Florida, 361 U.S. 847 (U.S. 1959)
- White v. Illinois, 361 U.S. 847 (U.S. 1959)
- Amoros v. State, 531 So. 2d 1256 (Fla. 1988)
- State v. Escobar, 570 So. 2d 1343 (Fla. 3d DCA 1990)
- Kem Dixon v. State, 627 So. 2d 1337 (Fla. 2d DCA 1993)