Santiago v. State, 2011 Fla. App. LEXIS 14982

Santiago was convicted of possession of cocaine, a lesser-included offense of trafficking in cocaine, in Palm Beach County, Florida.
Before trial, the State moved to admit Williams Rule evidence of a February 6, 2008 cocaine sale at the same residence where drugs were later seized.
On February 6, 2008, an undercover officer bought $40 of crack from Santiago, who used the nickname 'Snow' and had a gun on his person.
On February 20, 2008, police found cocaine, a gun, and marijuana at the residence; bags were labeled 'Snow' and one gun was hidden next to the drugs; an officer identified Santiago as the seller.
The jury convicted Santiago of possession of cocaine (lesser included offense); the trial court denied his motions for judgment of acquittal and for pre-trial Williams Rule admission.
On appeal, the Fourth District affirmed both the denial of judgment of acquittal on trafficking and the admission of Williams Rule evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for constructive possession	Edmond supports insufficiency; joint occupancy requires independent evidence	Independent incriminating evidence shows knowledge, dominion, control	Sufficient evidence; affirm conviction
Admissibility of Williams Rule evidence	Evidence should be excluded as improper propensity evidence	Evidence is relevant to knowledge/control and not substantially prejudicial	Admission not an abuse of discretion; Williams Rule evidence affirmed

Edmond v. State, 963 So.2d 344 (Fla. 4th DCA 2007) (constructive possession requires knowledge and dominion; joint occupancy requires independent evidence)
Fitzpatrick v. State, 900 So.2d 495 (Fla. 2005) (standard for judgment of acquittal; substantial evidence suffices if any viewed in light favorable to state)
State v. Law, 559 So.2d 187 (Fla. 1989) (possession elements under Florida trafficking statute)
Williams v. State, 110 So.2d 654 (Fla. 1959) ( Williams rule; collateral crimes evidence admissible for relevant issues other than propensity)
McLean v. State, 934 So.2d 1248 (Fla. 2006) (relevance and probative value vs. prejudice in collateral crime evidence)
Stav v. State, 860 So.2d 478 (Fla. 4th DCA 2003) (abuse of discretion standard for admissibility of Williams rule evidence)
Geldreich v. State, 763 So.2d 1114 (Fla. 4th DCA 1999) (probative value and prejudice balance in collateral crime evidence)
Parker v. State, 20 So.3d 966 (Fla. 3d DCA 2009) (prior transactions admitted only when relevant to a material issue of fact)
Audano v. State, 641 So.2d 1356 (Fla. 2d DCA 1994) (threshold relevancy; collateral crime evidence must prove material fact)