CHARLES HENRY WILLIAMS, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
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Charles Henry Williams appeals his convictions for sexual battery, kidnapping, robbery, and cocaine possession. The Florida appellate court affirms the convictions, finding no error in the trial court's admission of evidence regarding two other similar rape allegations committed by the defendant using an identical modus operandi.
The court held that the admission of collateral crimes evidence was proper because it established a common scheme or plan and was relevant to rebut the defense of consent. Evidence of similar facts relevant to a material fact in issue is admissible even if it points to the commission of another crime, unless the sole relevancy is character or propensity of the accused.
[1] Evidence of collateral crimes is admissible when it is relevant to a material fact in issue, unless the sole relevancy is to prove the character or propensity of the accu…
[2] Similar fact evidence, even if it points to the commission of another crime, is admissible if it is relevant to a material fact in issue.
Previewing 2 of 5 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“[T]he rule which we have applied in affirming this conviction simply is that evidence of any facts relevant to a material fact in issue except where the sole relevancy is character or propensity of the accused is admissible ... This rule we hold applies to relevant similar fact evidence ... even though it points to the commission of another crime.”
The controlling legal standard for admissibility of collateral crimes evidence, establishing that similar fact evidence is admissible if relevant to a material issue and not solely probative of character.
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Join FLexlaw to unlock all legal intelligenceWilliams engaged the victim in conversation about purchasing cocaine, then struck her in the head, choked her from behind, and placed a sharp object t…
The full statement of facts, procedural history, and disposition for this case are member content.
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GERSTEN, Judge.
Appellant, Charles Henry Williams, appeals his convictions for sexual battery, kidnapping, robbery and possession of co-' caine. We affirm.
After engaging the victim in conversation about where to purchase cocaine, appellant struck the victim in the head, choked her from behind, and put a sharp object to her neck. Appellant then dragged the victim to a secluded area where he threw her to the ground, took the victim’s cocaine, and then raped her. After his arrest, appellant admitted having sex with the victim, but claimed that it had been consensual. At trial, appellee, the State, introduced testimony of two other women who testified that they had also been raped by appellant in the same manner as the victim: engaging them in conversation about cocaine, grabbing them in a tight chokehold from behind, removing them to a secluded spot, taking their cocaine, and then raping them.
Appellant contends that the trial court erred in allowing the State to introduce collateral crimes evidence regarding the other rapes. The State asserts that admission of collateral crimes evidence was proper because the evidence established a common scheme or plan. The State also asserts that admission of the collateral crime evidence was necessary to rebut the defense of consent. The landmark case of Williams v. State, 110 So. 2d 654 (Fla.), cert. denied, 361 U.S. 847, 80 S.Ct. 102, 4 L.Ed.2d 86 (1959), established the rule regarding admissibility of collateral crime evidence:
[T]he rule which we have applied in affirming this conviction simply is that evidence of any facts relevant to a material fact in issue except where the sole relevancy is character or propensity of the accused is admissible ... This rule we hold applies to relevant similar fact evidence ... even though it points to the commission of another crime.
In Williams, as here, the defendant claimed that sex with the victim had been consensual. A second victim’s testimony was admitted to show plan, course of conduct, or common scheme. We find no error in the admission of the collateral crime evidence in this case. See Duckett v. State, 568 So. 2d 891 (Fla.1990; Eans v. State, 366 So. 2d 540 (Fla. 3d DCA 1979).
Finally, we find appellant’s other issues on appeal to be without merit, and deem any error in this case harmless, in light of the overwhelming evidence against appellant. See State v. DiGuilio, 491 So. 2d 1129 (Fla.1986). Accordingly, we affirm appellant’s convictions in all respects.
Affirmed.
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Williams v. State, 621 So. 2d 413 (Fla. 1993)…KOGAN, Justice. We have for review Williams v. State, 592 So. 2d 350 (Fla. 3d DCA 1992), because of apparent conflict with Hodges v. State, 403 So. 2d 1375 (Fla. 5th DCA 1981), review denied, 413 So. 2d 877 (Fla.1982); and Helton v. State, 365 So. 2d 1101 (Fla. 1st DCA), cert. denied, 373 So. 2d 461 (Fla.1979), on th…
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State v. Zenobia, 614 So. 2d 1139 (Fla. 4th DCA 1993)…kidnapping and sexual battery to the issues of the alleged victim’s consent and respondent’s plan, course of conduct or common scheme. The probative value of the evidence outweighs the danger of unfair prejudice to respondent. See Williams v. State, 592 So. 2d 350 (Fla. 3d DCA), juris, accepted, 606 So. 2d 1167 (Fla.1992); Jackson v. State, 538 So. 2d 533 (Fla. 5th DCA 1989). The record also shows the collateral evidence is relevant to the issue of respondent’s intent on the kidnapping count. See Gould v. Sta…
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Jacobs v. State, 861 So. 2d 112 (Fla. 3d DCA 2003)…PER CURIAM. Affirmed. See Williams v. State, 621 So. 2d 413 (Fla.1993), affirming, 592 So. 2d 350 (Fla. 3d DCA 1992); Houston v. State, 852 So. 2d 425 (Fla. 5th DCA 2003); cf. State v. Rickman, 861 So. 2d 1195, 2003 WL 22899976 (Fla. 2d DCA Case no. 2D02-4697, opinion filed, December 10, 2003)(Canady, J., concurring).…
Authorities Cited
- State v. DiGUILIO, 491 So. 2d 1129 (Fla. 1986)
- 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)
- Duckett v. State, 568 So. 2d 891 (Fla. 1990)
- Bishop v. State, 366 So. 2d 540 (Fla. 1st DCA 1979)