Coleman v. State, 126 So. 3d 1199

Appellant convicted of two counts of lewd and lascivious battery against a victim aged 12–15 in 2008.
State moved to admit Williams rule (similar fact) evidence of another molestation victim under Florida Statutes 90.404(2)(b)1 and 90.404(2)(a).
Williams rule victim testified to three 2008 incidents; victim aged fourteen; appellant allegedly forced intercourse without condom or words.
Williams rule victim testified to a 2007–2008 incident against another act; age indicated as sixteen/eighteen at hearing but trial record fixed it as younger for purposes of analysis.
Trial court identified nine similarities between the two incidents and held the Williams rule evidence admissible as similar fact and child molestation evidence; jury convicted counts I and II; defense appealed on admissibility and closing argument.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of Williams rule evidence under 90.404(2)(b) and (a)	Appellant: insufficient similarity to the charged act; prejudicial.	Appellee: statutory framework permits admission of other molestation acts; similarity supports relevance.	Evidence admissible; probative value outweighed prejudice.
Fundamental error in prosecutorial closing argument	Prosecutor's statements amount to fundamental error without objections.	No fundamental error; arguments not reversible.	Not fundamental error; affirm.

McLean v. State, 934 So.2d 1248 (Fla. 2006) (admissibility of prior molestations under 90.404(2)(b) discussed; balancing factors)
Tripoli v. State, 50 So.3d 776 (Fla. 4th DCA 2010) (abuse-of-discretion standard for admitting Williams rule evidence)
Trapp v. State, 57 So.3d 269 (Fla. 4th DCA 2011) (evidence rules constrain trial court discretion)
Wicklow v. State, 43 So.3d 85 (Fla. 4th DCA 2010) (prosecutorial misconduct; ad hominem attacks improper)
Palazon v. State, 711 So.2d 1176 (Fla. 2d DCA 1998) (remarks during closing argument; cautionary guidance)