Hart v. State, 2011 Fla. App. LEXIS 6760

Hart was charged in two separate cases: 16-2007-CF-1251-AXXX-MA with sexual battery, kidnapping, aggravated battery, and armed robbery; and 16-2007-CF-1250-AXXX-MA with carjacking.
The offenses occurred January 25, 2007, within a few hours and a few blocks of each other in the same neighborhood, using the same BB gun and involving stolen cell phones.
The State moved to join the charges for a single trial claiming intertwinement and the need to present all relevant evidence together.
The trial court granted joinder without explanation after a hearing, attaching the State’s motions to the orders.
The trial court’s joinder decision was reviewed under Rule 3.150(a), which allows joint trials only when offenses are based on the same act/transaction or connected acts with a meaningful link.
The First District Court of Appeal reversed the joinder, holding that the two episodes were freestanding and lacked a meaningful relationship, thus requiring severance for separate trials.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by joining the offenses for trial	Hart argued no meaningful link; joinder would prejudice guilt determinations.	State contends offenses were interrelated (same night, area, weapon, and evidence).	Joinder was improper; abuse of discretion; remand for severance.

Garcia v. State, 568 So. 2d 896 (Fla. 1990) (joinder must balance efficiency with fair trial rights)
Paul v. State, 385 So. 2d 1371 (Fla. 1980) (episodes joined only if they are part of an episodic whole)
Crossley v. State, 596 So. 2d 447 (Fla. 1992) (danger of bolstering one crime with evidence of another; need meaningful link)
Ellis v. State, 622 So. 2d 991 (Fla. 1993) (joinder requires a meaningful relationship beyond mere proximity)
Bundy v. State, 455 So. 2d 330 (Fla. 1984) (uninterrupted spree factors used to justify joinder)
Fotopoulos v. State, 608 So. 2d 784 (Fla. 1992) (causal link between crimes can justify joinder despite lapse)
Smithers v. State, 826 So. 2d 916 (Fla. 2002) (meaningful relationship may exist even when crimes are not a classic spree)
Puhl v. State, 426 So. 2d 1226 (Fla. 4th DCA 1983) (joinder improper where only similarity is a handgun)
Livingston v. State, 565 So. 2d 1288 (Fla. 1988) (joinder permissible where gun used was stolen in first robbery and used again)
Williams v. State, 110 So. 2d 654 (Fla. 1959) (Williams rule considerations re evidentiary use of similar acts)
Robertson v. State, 829 So. 2d 901 (Fla. 2002) (notice and individualized findings required for Williams rule evidence)