Johnson v. State
112 So. 3d 564
| Fla. Dist. Ct. App. | 2013Background
- Defendant Timothy Johnson and codefendant Deitrick Johnson were charged with eight counts of robbery with a firearm stemming from four robberies in Broward County in 2007.
- September 4, 2007 CVS Pharmacy robbery occurred; October 8, 2007 involved three chain pharmacy robberies; defendant allegedly served as lookout.
- State sought in limine to admit evidence of the September robbery as Williams rule collateral evidence for the October robberies; trial court admitted it.
- Codefendant previously had convictions upheld in related case; court noted numerous similarities among the robberies.
- Defendant moved to suppress his taped statements; court denied, and statements were used at trial; jury found Johnson guilty on all counts.
- Appeal focuses on whether admission of the September robbery as Williams rule evidence was reversible error; court held it was not.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of collateral crime evidence | State argues September robbery is relevant to MOI, identity, and plan. | Johnson contends it is unduly prejudicial and not probative beyond character evidence. | Court affirmed admission; evidence sufficiently similar, relevant, not unduly prejudicial. |
Key Cases Cited
- Williams v. State, 110 So.2d 654 (Fla. 1959) (Williams rule admissibility for collateral crimes)
- DeLuise v. State, 72 So.3d 248 (Fla. 4th DCA 2011) (limits on admissibility of Williams rule evidence)
- Alsfield v. State, 22 So.3d 619 (Fla. 4th DCA 2009) (relevance and probative value balancing)
- Pulcini v. State, 41 So.3d 338 (Fla. 4th DCA 2010) (abuse of discretion standard for collateral evidence rulings)
- Johnson v. State, 110 So.3d 954 (Fla. 4th DCA 2018) (precedent on similar evidence in related case)