EDDIE LEE RICHARDSON, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Eddie Lee Richardson's convictions for cocaine possession and sale were reversed because the trial court improperly admitted evidence of a metal matchbox containing cocaine residue found at his arrest. The matchbox was not tied to any of the charged offenses and was admitted solely to show propensity to possess cocaine, violating the Williams Rule.
The trial court improperly admitted the matchbox evidence because it was admitted solely to show propensity to possess cocaine at an earlier time, which is inadmissible under the Williams Rule. Unlike a bloody knife found at a murder scene, nothing tied the matchbox to any of the charges against Richardson, making the similar fact evidence irrelevant for any permissible purpose.
[1] Evidence of possession of a controlled substance at the time of arrest is inadmissible to prove possession of the same substance at an earlier time, absent a specific cha…
[2] Similar fact evidence is inadmissible when offered solely to prove bad character or propensity.
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“The trial court admitted the matchbox and testimony that it contained cocaine, over defense objection, on the premise that possession at the time of arrest went to the issue of whether appellant possessed cocaine earlier.”
Describes the trial court's reasoning for admitting the evidence and the improper basis for doing so.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceRichardson was charged with three counts of possession and three counts of sale of cocaine based on controlled buys conducted several hours before his…
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BARFIELD, Judge.
Appellant’s convictions for three counts of possession and three counts of sale of cocaine are reversed. The trial court improperly admitted evidence of a metal matchbox containing cocaine residue which was found on appellant at the time of his arrest.
The crimes charged arose from several controlled buys of cocaine made several hours before the arrest. The matchbox was in no way implicated in the charges as no evidence showed it was used in the sales. No separate charge related to possession of cocaine at the time of the arrest was brought by the state. The trial court admitted the matchbox and testimony that it contained cocaine, over defense objection, on the premise that possession at the time of arrest went to the issue of whether appellant possessed cocaine earlier. The trial court found no violation of the Williams Rule1 in admitting such evidence. The trial court likened the matchbox to a bloody knife found on a suspect in a knife murder which would be proper evidence, even if the state did not bring a separate weapons charge. We disagree, finding that the evidence of the matchbox was admitted solely to show propensity to possess cocaine at an earlier time, evidence which is inadmissible under the Williams Rule. The trial court admitted as much in allowing admission of the evidence. However, nothing tied the matchbox to any of the charges against appellant, unlike the knife to which the trial court analogized. This similar fact evidence was not offered for any permissible purpose under the Williams Rule. It was therefore admitted for an improper evidentiary purpose.
Accordingly, the convictions and sentence are REVERSED and the case REMANDED for a new trial.
THOMPSON, J., concurs.
NIMMONS, J., dissents without opinion.
. Williams v. State, 110 So. 2d 654 (Fla.), cert. den., 361 U.S. 847, 80 S.Ct. 102, 4 L.Ed.2d 86 (1959), now codified at section 90.404(2)(a), Florida Statutes: "Similar fact evidence of other crimes, wrongs, or acts is admissible when relevant to prove a material fact in issue, such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident, but it is inadmissible when the evidence is relevant solely to prove bad character or propensity."
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Avery Simmons v. State, 541 So. 2d 171 (Fla. 4th DCA 1989)…benefit of the court on remand, that it was error to allow testimony regarding a marijuana cigarette found in the room. Cf. Williams v. State, 110 So. 2d 654 (Fla.), cert. denied, 361 U.S. 847, 80 S.Ct. 102, 4 L.Ed.2d 86 (1959); Richardson v. State, 528 So. 2d 981 (Fla. 1st DCA 1988). It was also error to give a principals instruction where the only charge against the defendant was the (constructive) possession of the drugs found in the room based on the [*172] defendant’s individual occupancy and control. We…
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Carr v. State, 578 So. 2d 398 (Fla. 1st DCA 1991)…er admission of the cash invited conjecture on the part of the jury that Jackson was involved in other unproven criminal conduct, making it more likely that he could be guilty of the charged offense. 570 So. 2d at 1389. See also Richardson v. State, 528 So. 2d 981 (Fla. 1st DCA 1988). In the instant case, the trial court admitted evidence of appellant’s prior conviction for possession of cocaine for the purpose of showing knowledge of cocaine. Here, as in Keen and Jackson, the real jury issue was appellant’s…
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Hawks v. State, 616 So. 2d 1106 (Fla. 5th DCA 1993)…stimony of state's witness that defendant had given her cocaine and thereafter caused her to start selling cocaine to support her habit was not relevant to charges of trafficking in cocaine and conspiracy to traffic in cocaine); Richardson v. State, 528 So. 2d 981 (Fla. 1st DCA 1988) (evidence of metal matchbox containing cocaine residue found on defendant at time of his arrest should not have been admitted in prosecution for possession and sale of cocaine, since matchbox was admitted solely to show propensit…
Previewing 3 of 4 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities 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)