Ricketts v. State
125 So. 3d 194
| Fla. Dist. Ct. App. | 2013Background
- Defendant convicted of unlawfully possessing cannabis in excess of 25 pounds under Florida Statutes § 893.135(1)(a) and related possession/conspiracy provisions.
- State offered Williams rule evidence (other crates) to prove knowledge, dominion, and a continuing scheme connecting crates to the charged cannabis.
- Crates included similar packaging, nails, wood, and California addresses; some crates were in a storage unit rented by the defendant under an assumed name.
- A crate containing cannabis produced odor detectable by a drug-sniffing K9, supporting likelihood of knowledge and possession.
- Trial court admitted the crates evidence over defense objection; the issue on appeal is admissibility and whether it was unduly prejudicial.
- Court notes the Florida Supreme Court recently held Chapter 893 constitutional on its face in State v. Adkins.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Williams rule evidence | State argues crates show continuing scheme and knowledge. | Polen argues evidence is improper collateral crime evidence and prejudicial. | Admissible; not abuse of discretion. |
| Whether knowledge and continuing scheme were proven by the crates | State contends crates establish knowledge and control over cannabis. | Polen contends crates do not prove knowledge beyond propensity. | Knowledge and scheme shown; evidence properly admitted. |
| Risk of unfair prejudice from Williams rule evidence | Evidence focus remained on charged cannabis; probative value high. | Evidence could prejudice jury against defendant. | Probative value not substantially outweighed by prejudice. |
| Facial constitutionality of § 893.135 | Statute constitutional as charged. | § 893.135 facially unconstitutional. | Statute constitutional on its face. |
Key Cases Cited
- Santiago v. State, 70 So.3d 720 (Fla. 4th DCA 2011) (Williams rule admissibility; continuing scheme; probative value balancing)
- DeLuise v. State, 72 So.3d 248 (Fla. 4th DCA 2011) (collateral crime evidence; focus on prosecution; closing argument impact)
- State v. Adkins, 96 So.3d 412 (Fla. 2012) (Chapter 893 constitutional on its face)