125 So. 3d 213
Fla. Dist. Ct. App.2013Background
- The State sought certiorari to challenge a circuit court order sustaining the defendant’s objection to Williams rule evidence in two related cases involving alleged molestations of family members.
- In one case, the defendant was charged with lewd or lascivious molestation of his daughter, A.S.; in the other, he faced one count of sexual battery in a position of familial/custodial authority and two counts of lewd or lascivious molestation of his stepdaughter, M.H.
- The State filed notices to admit alleged acts from the other case as Williams rule evidence, which the defendant objected to in both matters.
- A pretrial evidentiary hearing featured testimony from M.H. (age 22) about multiple past acts and from A.S. (age 13) about a single alleged incident, with the acts from years earlier.
- The circuit court entered a written order excluding the Williams rule evidence, citing concerns that the prior acts were unnecessary to describe charged conduct and that the acts were too temporally separate and prejudicial.
- The State petitioned for certiorari, arguing the court misapplied the inextricably intertwined standard and failed to apply McLean v. State’s framework for Williams rule analysis; the court agreed and granted relief, remanding to apply McLean properly.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the circuit court properly admitted Williams rule evidence under McLean | State contends McLean steps were not followed | Williams rule evidence should be narrowly limited and non-prejudicial | Remand to apply McLean steps; improper McLean analysis |
| Whether the court erred in applying the inextricably intertwined standard | Inextricably intertwined is misapplied; not controlling law here | Evidence is inextricably intertwined with the charged acts | First finding improper; requires McLean-based analysis |
| Whether the pretrial ruling caused a miscarriage of justice requiring certiorari relief | Pretrial ruling substantially impaired the State’s ability to prove acts of molestation | Ruling did not prejudice the State; proper safeguards exist | Petition granted; miscarriage of justice found |
Key Cases Cited
- McLean v. State, 934 So.2d 1248 (Fla. 2006) (establishes McLean four-factor framework for Williams rule evidence)
- Ward v. State, 59 So.3d 1220 (Fla. 4th DCA 2011) (definition of inextricably intertwined evidence)
- Pettis, 520 So.2d 250 (Fla. 1988) (certiorari relief requires violation of clearly established law causing miscarriage)
- Sealy-Doe, 861 So.2d 530 (Fla.4th DCA 2003) (certiorari standard for pretrial evidentiary rulings)
- State v. Tameris, 54 So.3d 619 (Fla. 5th DCA 2011) (remand permitted to address McLean factors in similar fact evidence rulings)
- Williams v. State, 110 So.2d 654 (Fla. 1959) (background Williams rule lineage)