JOEY ALLEN REYES, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE; JOEY ALLEN REYES, APPELLANT, V. STATE OF FLORIDA, APPELLEE
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The court held that the State improperly introduced evidence of unrelated prior crimes on rebuttal, which prejudiced the defendant and warranted reversal.
[1] Evidence of unrelated prior crimes is inadmissible in a criminal prosecution for the purpose of showing a defendant's character or propensity to commit a crime.
[2] Rebuttal evidence of unrelated prior crimes is inadmissible when no predicate for its introduction was laid during the defendant's case.
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Join FLexlaw to unlock all legal intelligenceThe defendant was on trial for possession and sale of illegal drugs. The State introduced extensive rebuttal testimony about the defendant's prior unr…
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By this appeal, Reyes seeks a reversal of judgments of guilt for the crimes of possession of illegal drugs and sale of illegal drugs.
We are primarily concerned with appellant’s first point on appeal, viz.: Whether or not the State may, in a criminal prosecution, introduce evidence of other unrelated crimes on rebuttal when no predicate for the introduction of the evidence was laid during the defendant’s case.
At the conclusion of defendant’s case, the State adduced a number of witnesses who testified for a period of almost two days as to prior illegal drug transactions indulged in by defendant. At this stage, the trial progressively developed into a general inquiry as to defendant’s character, his propensity to indulge in criminal activities and the numerous crimes he had committed over a long period of time. One hundred forty-one pages of this record is devoted to the alleged impeachment of defendant’s testimony that he had not used drugs, other than those which were prescribed, prior to the date of his arrest. The rebuttal testimony is replete with evidence of prior specific crimes and hearsay testimony. The feature of the trial quickly faded into the spotlight of a sideshow focusing on the character, general reputation and propensity of defendant Reyes to engage in criminal activities. The Anglo-Saxon system of jurisprudence has not sanctioned such trials since the era of the Star Chamber.
The State argues that Williams v. State1 stands for the proposition that evidence relating to similar facts, even though the evidence may point to the commission of a separate crime, is admissible in a crim*908inal trial if relevant for any purpose save that of showing bad character or propensity to commit a crime. The key word contained in Williams is “relevant”, and here “relevancy” is absent. In addition, the State contends that if this Court should hold that the subject testimony was not admissible under the “relevant” theory or for impeachment purposes, same falls within the “harmless error” doctrine.2 As observed, the spotlight focused on the sideshow of unrelated past activities of defendant Reyes and it is difficult to envision how the jury could possibly not have been influenced by this inadmissible evidence. In this jurisdiction, a citizen accused of committing a crime, no matter how heinous or reprehensible it may be in the eyes of society, is entitled to be informed as to the nature of the charge against him and afforded the opportunity to prepare his defense prior to being put to trial. Such was not done in the instant cause and it is our duty to reverse.
In Abram v. State3 a judgment of conviction for first degree murder was reversed because the State erroneously introduced into evidence an illegally obtained confession. Speaking for this Court, Judge Wigginton stated:
“ * * * We reach this conclusion with considerable reluctance because the record reflects overwhelming eyewitness testimony establishing defendant’s guilt of the crime charged. The purported confession made by him was merely cumulative and added little if anything to the evidence already adduced concerning defendant’s guilt. Under the circumstances we find it most difficult to understand why the prosecuting officer was willing to incur the risk of reversal by insisting upon the admission into evidence of the illegal confession * * * in view of the highly questionable necessity for doing so. By taking such risk, the expense of the initial trial has been wasted and the time of the trial court and this court in considering this case has been needlessly encumbered. The necessity for reversing convictions of this kind in order to assume compliance with the technical requirements of law causes consternation among laymen and brings the entire judicial system into disrepute. It is to be hoped that instances such as this will be avoided in the future by those charged with the prosecution of crime in our state.”
We observe that the foregoing is applicable to the instant cause.
Reversed and remanded with directions to grant defendant a new trial.
CARROLL, DONALD K., Acting C. J., and JOHNSON, J., concur.
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Cited By (11 total)
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Sias v. State, 416 So. 2d 1213 (Fla. 3d DCA 1982)…reversals have followed. See, e.g., Williams v. State, 117 So. 2d 473 (Fla.1960); Knox v. State, 361 So. 2d 799 (Fla. 1st DCA 1978); Davis v. State, 276 So. 2d 846 (Fla. 2d DCA 1973), aff’d, State v. Davis, 290 So. 2d 30 (Fla.1974); Reyes v. State, 253 So. 2d 907 (Fla. 1st DCA 1971); Green v. State, 228 So. 2d 397 (Fla. 2d DCA 1969). Concededly, the record in the present case reflects that more time was spent and evidence presented on the collateral crime. However, this disproportion did not come about becau…
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Snowden v. State, 537 So. 2d 1383 (Fla. 3d DCA 1989)…re instead of an incident” of the trial on the charged offense where it could be said that the similar fact evidence had so overwhelmed the evidence of the charged crime as to be considered an impermissible character attack. Thus, in Reyes v. State, 253 So. 2d 907, 907 (Fla. 1st DCA 1971), the court declared that “At the conclusion of defendant’s case, the State adduced a number of witnesses who testified for a period of almost two days as to prior illegal drug transactions indulged in by defendant. At this…
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Simmons v. Louie L. Wainwright, 271 So. 2d 464 (Fla. 1st DCA 1973)…edge hammer. The State by its brief argues that appellant urges “this Court once again pervert the holding in Williams v. State, 110 So. 2d 654 (Fla.1959) as interpreted in the cases of Lucas v. State, 257 So. 2d 261 (1 DCA 1972) and Reyes v. State, 253 So. 2d 907 (1 DCA 1971).” This court has not perverted the holding in Williams v. State, but to the contrary has set forth certain guidelines to restrict a trial to the offense lodged in the information or indictment and urged those entrusted with the duty of…
Previewing 3 of 11 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)
- Goddard v. State, 143 Fla. 28 (Fla. 1940)
- Coppolino v. State, 223 So. 2d 68 (Fla. 2d DCA 1968)
- Mahone v. State, 222 So. 2d 769 (Fla. 3d DCA 1969)
- State v. Wadsworth, 210 So. 2d 4 (Fla. 1968)
- Abram v. State, 216 So. 2d 498 (Fla. 1st DCA 1968)