ERIC EDWARD PRATT, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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The court held that the trial court erred in admitting prior bad acts evidence because it only demonstrated propensity and was not relevant to any contested issue.
[1] Evidence of prior bad acts is inadmissible when its sole purpose is to demonstrate a defendant's propensity for criminal conduct.
[2] To be admissible, evidence of prior similar crimes must be relevant to a material fact in issue and share unique characteristics with the charged offense, distinguishing…
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Join FLexlaw to unlock all legal intelligenceThe defendant was on trial for aggravated battery against his wife and stepdaughter. The State sought to introduce evidence of three prior incidents w…
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Defendant was on trial for aggravated battery in the beating of his stepdaughter and pregnant wife. The State sought to present evidence that during the 18 months preceding the beatings, defendant had beaten his wife on 3 different occasions — the most recent barely a few months before the alleged crimes. The judge allowed this Williams rule1 evidence over the objection of defendant. We reverse.
These are the events. One morning the daughter heard defendant say something to the effect that he was unhappy with the mother and stepdaughter. Hearing footsteps behind her, the daughter turned around and defendant punched her in the face. As she lay on the ground, defendant hit her in the face with a ceramic object. She passed out briefly and awoke to hear her mother screaming while trying to pick her up. Whereupon defendant began punching her mother, who tried to run from him. Defendant caught her and hit her again. Mother fell to the ground, and defendant grabbed her by her robe and dragged her into the living room. Mother tried to run out the front door, but defendant fell upon her again, while the daughter tried to pull him from her. Defendant continued hitting her, and then turned toward daughter who, by then, was attempting to call police. A neighbor saw the events at the front door and summoned help. Defendant drove away before police arrived.
This is the Williams rule evidence. In the oldest incident, defendant had pushed his wife into a wall. In the second he had pushed her into the sink. And in the most recent to the crimes on trial, he had pulled a door from its hinges and hit her in the back of her head. Nothing in the similar crimes evidence pointed to a signature crime or some unique feature of the aggravated battery charges on trial.
The State’s theory of relevance as to the Williams rule evidence is that it proved motive, intent, or absence of mistake or accident, or rebutted a possible claim of self-defense. In allowing this evidence the trial court held that it was relevant to the issues of intent, motive, absence of mistake and to rebut self-defense.
In the circumstances of this case, these earlier incidents of violence do nothing more than demonstrate his propensity for violence with his family members. Neither party did anything to make motive or intent significant to any contested fact. No one suggested any factual issue as to a specific reason for battering the two women. Nor did he claim that his actions were by mistake. Motive, intent and mistake were simply not made pertinent issues in the trial.
This leaves self-defense as the basis for admitting Williams rule evidence. Defendant did not make self-defense an issue with regard to his wife. His defense was instead that he never hit her. Yet the Williams rule evidence was admitted as part of the State’s case in chief, not as a response to evidence presented by defen*1171dant seeking to make a case for self-defense.
It is well accepted that evidence of past crimes is not admissible when its only function is to show a propensity for the criminal conduct on trial. McLean v. State, 934 So.2d 1248, 1255 (Fla.2006). It is also settled that Williams rule evidence must meet a high standard of relevance, be strikingly similar to the crime charged and share some unique characteristics distinguishing the past crime and the crime on trial from other offenses. Macias v. State, 959 So.2d 782, 785 (Fla. 4th DCA 2007). Even then the proponent of the evidence must demonstrate that its probative value is greater than the unfair prejudice associated with such evidence. McLean, 934 So.2d at 1256. The evidence in this case satisfies none of these requirements.
Erroneous admission of collateral crimes evidence is presumptively harmful. Robertson v. State, 829 So.2d 901, 913-14 (Fla.2002); Gore v. State, 719 So.2d 1197, 1199 (Fla.1998); Czubak v. State, 570 So.2d 925, 928 (Fla.1990); Castro v. State, 547 So.2d 111, 116 (Fla.1989); Straight v. State, 397 So.2d 903, 908 (Fla.), cert. denied; 454 U.S. 1022, 102 S.Ct. 556, 70 L.Ed.2d 418 (1981). The error may be found harmless only “if it can be said beyond a reasonable doubt that the verdict could not have been affected by the error.” Ciccarelli v. State, 531 So.2d 129, 132 (Fla. 1988). We are unable to say beyond a reasonable doubt that the admission was harmless.
Reversed.
POLEN and HAZOURI, JJ., concur.
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Pulcini v. State, 41 So. 3d 338 (Fla. 4th DCA 2010)…te, 25 So. 3d 49, 54 (Fla. 1st DCA 2009) (citing State v. DiGuilio, 491 So. 2d 1129, 1139 (Fla.1986)). Erroneous admission of collateral crimes evidence is presumptively harmful. Robertson v. State, 829 So. 2d 901, 913-14 (Fla.2002); Pratt v. State, 1 So. 3d 1169, 1171 (Fla. 4th DCA 2009). This is particularly the case where, as here, the prior acts and charged offense are sexually based. See McLean, 934 So. 2d at 1256 (“Because of the commonly held belief that individuals who commit sexual assaults are more…
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Harden v. State, 87 So. 3d 1243 (Fla. 4th DCA 2012)…e probative value of the evidence outweighed the prejudicial effect). However, where intent or motive is not a material fact at issue, the collateral crime evidence cannot be admitted for the purpose of showing intent or motive. See Pratt v. State, 1 So. 3d 1169 (Fla. 4th DCA 2009). In Pratt, this court held that in a prosecution for aggravated battery of the defendant’s wife and daughter, it was error to admit evidence of three prior beatings of the wife by defendant during the preceding eighteen months. W…
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Jackson v. State, 140 So. 3d 1067 (Fla. 1st DCA 2014)…[his or her] intent.”). Accordingly, because intent was not a material issue in dispute, the trial court erred in allowing the State to introduce the Williams rule evidence to prove Jackson’s intent to commit the charged crimes. See Pratt v. State, 1 So. 3d 1169, 1170-71 (Fla. 4th DCA 2009) (reversing admission of collateral-crime evidence that defendant beat his wife three times in the 18 months preceding the charged crime to show motive or intent because the defendant denied committing the charged crime a…
Previewing 3 of 5 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited (11 total)
- Williams v. State, 110 So. 2d 654 (Fla. 1959)
- Straight v. State, 397 So. 2d 903 (Fla. 1981)
- Swett v. State, 829 So. 2d 901 (Fla. 2002)
- Czubak v. State, 570 So. 2d 925 (Fla. 1990)
- McLEAN v. State, 934 So. 2d 1248 (Fla. 2006)
- Gore v. State, 719 So. 2d 1197 (Fla. 1998)
- Robertson v. State, 829 So. 2d 901 (Fla. 2002)
- Tucker v. Zant, 454 U.S. 1022 (U.S. 1981)
- Castro v. State, 547 So. 2d 111 (Fla. 1989)
- Ciccarelli v. State, 531 So. 2d 129 (Fla. 1988)