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Williams Rule
Encyclopedia
The Williams Rule is based on the holding in the Florida
state case of Williams v. Florida, 110 So. 2d 654 (Fla., 1959) in which relevant evidence
of collateral crimes is admissible at jury trial
when it does not go to prove the "bad character" or "criminal propensity" of the defendant
but is used to show motive, intent, knowledge, modus operandi
, or lack of mistake.
Following cases in the state have molded and defined the applicability of the Williams rule in criminal cases. Varying standards of "relevance" seem to apply depending on the prong of the rule applied.
The legislature of Florida has also memorialized the Williams Rule in Florida Statute sec. 90.404(2)(a).
In Akers v. State, 352 So. 2d 97, the Florida Fourth District Court of Appeal
clarified that evidence of another crime cannot be introduced unless some relevancy to the trial at hand is shown by evidence. In Akers, the court stated that "[i]f prosecutors insist on crying the wolf of the Williams Rule they might eventually find the courts hard of hearing." Critics of the way the Williams Rule is often used by the prosecution say that trial courts fail to require the requisite showing of relevance to the current issues before allowing the Williams Rule evidence to be introduced. As such, these critics claim that the evidence is in fact being used to show the bad character and criminal propensity of the defendant. Such a use is prohibited by the rules of evidence.
Florida
Florida is a state in the southeastern United States, located on the nation's Atlantic and Gulf coasts. It is bordered to the west by the Gulf of Mexico, to the north by Alabama and Georgia and to the east by the Atlantic Ocean. With a population of 18,801,310 as measured by the 2010 census, it...
state case of Williams v. Florida, 110 So. 2d 654 (Fla., 1959) in which relevant evidence
Evidence (law)
The law of evidence encompasses the rules and legal principles that govern the proof of facts in a legal proceeding. These rules determine what evidence can be considered by the trier of fact in reaching its decision and, sometimes, the weight that may be given to that evidence...
of collateral crimes is admissible at jury trial
Jury trial
A jury trial is a legal proceeding in which a jury either makes a decision or makes findings of fact which are then applied by a judge...
when it does not go to prove the "bad character" or "criminal propensity" of the defendant
Defendant
A defendant or defender is any party who is required to answer the complaint of a plaintiff or pursuer in a civil lawsuit before a court, or any party who has been formally charged or accused of violating a criminal statute...
but is used to show motive, intent, knowledge, modus operandi
Modus operandi
Modus operandi is a Latin phrase, approximately translated as "mode of operation". The term is used to describe someone's habits or manner of working, their method of operating or functioning...
, or lack of mistake.
Following cases in the state have molded and defined the applicability of the Williams rule in criminal cases. Varying standards of "relevance" seem to apply depending on the prong of the rule applied.
The legislature of Florida has also memorialized the Williams Rule in Florida Statute sec. 90.404(2)(a).
In Akers v. State, 352 So. 2d 97, the Florida Fourth District Court of Appeal
Florida Fourth District Court of Appeal
The Florida Fourth District Court of Appeal is headquartered in West Palm Beach, Florida. Its twelve judges have jurisdiction over cases arising in Palm Beach County, Broward County, St. Lucie County, Martin County, Indian River County, and Okeechobee County....
clarified that evidence of another crime cannot be introduced unless some relevancy to the trial at hand is shown by evidence. In Akers, the court stated that "[i]f prosecutors insist on crying the wolf of the Williams Rule they might eventually find the courts hard of hearing." Critics of the way the Williams Rule is often used by the prosecution say that trial courts fail to require the requisite showing of relevance to the current issues before allowing the Williams Rule evidence to be introduced. As such, these critics claim that the evidence is in fact being used to show the bad character and criminal propensity of the defendant. Such a use is prohibited by the rules of evidence.