R. C. KNOX, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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R.C. Knox appealed his conviction for lewd and lascivious conduct with a minor, challenging the admission of evidence regarding a separate incident and the sufficiency of evidence regarding intent. The court reversed and remanded for a new trial due to a Williams rule violation, finding that evidence of a subsequent incident was highly prejudicial and improperly used to show propensity.
The admission of evidence regarding the May 22 incident constituted reversible error under the Williams rule because it was prejudicial and only relevant to show propensity. The court affirmed the holding that a defendant cannot escape punishment by claiming his intent was to commit a higher crime rather than the crime charged.
[1] Evidence of a subsequent, collateral incident is inadmissible when its sole relevance is to show a defendant's propensity to commit the crime charged.
[2] The prejudicial effect of evidence of a collateral incident outweighs its relevance when it is not used to prove intent, motive, absence of mistake, modus operandi, or an…
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Join FLexlaw to unlock all legal intelligence“It is obvious on this record that the State's confusion about the date of the incident witnessed by the mother led to the admission of the evidence on the subsequent incident, which was highly prejudicial to the appellant in defending against the charge on the May 21 offense.”
Establishes the basis for the Williams rule violation and the prejudicial error requiring reversal
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Join FLexlaw to unlock all legal intelligenceKnox was charged with handling, fondling, or making an assault on his step-daughter in a lewd manner on May 21, 1977, between 4 p.m. and 3 a.m. the ne…
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PER CURIAM.
Appellant, convicted below of a violation of Section 800.04, Florida Statutes (1975), appeals his judgment and sentence on the basis of a “ Williams rule” violation and on grounds that the State failed to prove the necessary intent to convict him of the crime charged. We find merit in the first point and reverse.
The record reveals that appellant was charged by information with “handling, fondling, or making an assault upon his step-daughter, Barbara Jean Daughtery, a child under the age of 14 years in a lewd, lascivious and indecent manner without the intent to commit involuntary sexual battery, on May 21,1977.” The bill of particulars requested by appellant specified that the offense took place “between 4 o’clock p. m. on May 21, 1977, and 3 o’clock a. m. on May 22,1977.” At trial, however, the prosecutor in his opening comments outlined an offense which took place late on the night of May 22. Appellant’s wife then testified for the State that she had witnessed an incident between her husband and her daughter on the night of May 22. The daughter then testified to two incidents, one on the night of May 22, which her mother testified that she had witnessed, and another one on the previous night (within the time specified in the bill of particulars) which according to her testimony had occurred outside of the presence of her mother. The State also introduced evidence of a statement made by appellant in which he had admitted having various sexual relations with his step-daughter over an 18-month period. Appellant was convicted by the jury of the offense which had allegedly occurred on the night of May 21 out of the presence of the mother.
Appellant claims first that it was a violation of the “ Williams rule”1 for the State to present evidence of the May 22 incident throughout his trial on the May 21 incident.
We agree. It is obvious on this record that the State’s confusion about the date of the incident witnessed by the mother led to the admission of the evidence on the subsequent incident, which was highly prejudicial to the appellant in defending against the charge on the May 21 offense. We believe that the prejudicial effect of this evidence outweighed any possible relevance it may have had.
The evidence here of the subsequent incident was not relevant to prove appellant’s intent, motive, absence of mistake, modus operandi, or any other element of the crime charged. Its only relevance was to show appellant’s propensity to commit the crime, which is clearly improper. Banks v. State, 298 So. 2d 543 (Fla. 1 DCA 1974); Harris v. State, 183 So. 2d 291 (Fla. 2 DCA 1966); Hooper v. State, 115 So. 2d 769 (Fla. 3 DCA 1959).
Moreover, the evidence of the collateral incident here became the “featured” evidence, in violation of this Court’s opinion in Reyes v. State, 253 So. 2d 907 (Fla. 1 DCA 1971).
We conclude that the admission into this trial of the testimony regarding the collateral incident and the appellant’s statement about his ongoing relations with his step-daughter violated the Williams rule and constituted reversible error. Appellant’s next point, regarding the sufficiency of the evidence to prove his guilt of a violation of Section 800.04 because the State did not prove his “negative intent”, i. e., his intent not to commit involuntary battery, has recently been discussed in Matava v. State, 358 So. 2d 1116 (Fla. 3d DCA 1978).
We agree with the Court’s holding there that “a defendant may not escape punishment for the offense upon the basis that his mental attitude or intention was actually to commit the higher crime of involuntary sexual battery.”
The final judgment is reversed as to Point I and affirmed as to Point II and the case is remanded for a new trial.
McCORD, C. J., and MILLS and ERVIN, JJ., concur. . Williams v. State, 110 So. 2d 654 (Fla.1959).
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Citator
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Cotita v. State, 381 So. 2d 1146 (Fla. 1st DCA 1980)…for a variety of reasons depending on the facts and issues involved, as in trial of other crimes. Similar fact evidence has been properly disallowed where its probative value was slight or where its effect was unduly prejudicial. In Knox v. State, 361 So. 2d 799 (Fla. 1st DCA 1978), this court correctly reversed a conviction under Florida Statute § 800.04. In that case the defendant was charged with a specific sex offense against his thirteen-year-old stepdaughter, stated to have occurred on May 21. The Sta…1 / 2
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Sias v. State, 416 So. 2d 1213 (Fla. 3d DCA 1982)…ect.” Id. at 475-76 (emphasis in original). Where the evidence of the other crime is found to be so disproportionate as to become a feature of the case, 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…
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Snowden v. State, 537 So. 2d 1383 (Fla. 3d DCA 1989)…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.” See also Matthews v. State, 366 So. 2d 170 (Fla. 3d DCA 1979); Knox v. State, 361 So. 2d 799 (Fla. 1st DCA 1978). It is well settled, then, that the rule “that the State should not be permitted to make the evidence of other crimes the feature of the trial” is a limitation on the rule of relevancy. Bryan v. State, 533 So. 2d 744, 746 (Fla.19…
Previewing 3 of 9 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)
- Jackson Holloway Hooper v. State, 115 So. 2d 769 (Fla. 3d DCA 1959)
- Harris v. State, 183 So. 2d 291 (Fla. 2d DCA 1966)
- Howard Banks v. State, 298 So. 2d 543 (Fla. 1st DCA 1974)
- Reyes v. State, 253 So. 2d 907 (Fla. 1st DCA 1971)
- Matava v. State, 358 So. 2d 1116 (Fla. 3d DCA 1978)