Kirkland-Williams v. State, 230 So. 3d 580

Defendant Damarcus J. Kirkland-Williams was charged with first‑degree felony murder (while engaged in aggravated child abuse) and aggravated child abuse after 13‑month‑old E.M. died of blunt‑force trauma and internal lacerations.
Williams told detectives E.M.'s injuries were accidental (struck/back‑squeezed/tossed; fell and hit dresser).
The State sought to admit Williams rule (similar‑fact) evidence: a video and eyewitness testimony showing Williams, less than three weeks earlier, repeatedly striking F.M. (E.M.'s two‑year‑old sister) with a blunt object.
At a pretrial Williams hearing the court found the incidents closely similar (age, caretaker status, crying before abuse, blunt‑force injuries, temporal proximity) and admitted the evidence to show absence of accident, intent, identity, and opportunity.
The jury was instructed on proper use of the Williams rule evidence; Dr. Mary Mainland (medical examiner) testified E.M.'s injuries were consistent with repeated blunt strikes.
Jury convicted on both counts; Williams received life for murder and 30 years for aggravated child abuse.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of Williams rule evidence (relevance vs. unfair prejudice)	State: similar‑fact evidence admissible to show absence of accident, intent, identity, opportunity given strong similarities and temporal proximity	Williams: evidence irrelevant because defense was denial of causing injuries (not accident); alternatively, unfairly prejudicial and suggested propensity to harm children	Court: Admission not an abuse of discretion — evidence was relevant to rebut pretrial accidental‑injury statements and to prove intent/identity/opportunity; probative value outweighed prejudice; jury instructed accordingly
Sufficiency of State's notice to rely on Williams rule evidence	State: timely filed notice and supplement specifying acts and explaining relevancy (identity, intent, absence of mistake, plan, opportunity)	Williams: notice defective under Zenobia for failing to state which particular aspect (motive/intent/etc.) it sought to prove	Court: Notice satisfied §90.404(2)(d)(1); supplement provided adequate detail and was filed >10 days before trial; Zenobia's stricter rule rejected in favor of more flexible notice standard

Estelle v. McGuire, 502 U.S. 62 (1991) (Williams‑rule evidence admissible to show absence of accident and intent even if accident defense not raised at trial)
Wright v. State, 19 So. 3d 277 (Fla. 2009) (similar‑fact evidence admissible to prove material facts like absence of mistake or accident)
Pausch v. State, 596 So. 2d 1216 (Fla. 2d DCA 1992) (Williams‑rule evidence admissible to show absence of accidental death)
Barber v. State, 781 So. 2d 425 (Fla. 5th DCA 2001) (collateral offense testimony admissible to show identity, opportunity, intent, absence of mistake, and common plan)
McLean v. State, 934 So. 2d 1248 (Fla. 2006) (probative value of collateral‑offense evidence not substantially outweighed by prejudice when limited and accompanied by jury instructions)
Evans v. State, 693 So. 2d 1096 (Fla. 3d DCA 1997) (prior incident two months earlier not too remote for collateral‑crime relevance)
Zenobia v. State, 614 So. 2d 1139 (Fla. 4th DCA 1993) (held notice insufficient for failure to specify which material fact the evidence would prove)
Quinn v. State, 662 So. 2d 947 (Fla. 1995) (rejecting Zenobia's requirement that notice specify particular aspect the State intends to prove)