State v. Williams
134 Ohio St. 3d 521
Ohio2012Background
- Williams, charged with multiple sexual offenses against J.H., began abusing him in 2008 when J.H. was 14 after mentoring him through church connections.
- The State sought to admit evidence of a prior relationship Williams had with A.B., a different teenage boy, to show a scheme, plan, or grooming method.
- A.B.'s testimony was admitted with limiting instructions; defense had suggested J.H. was lying or mistaken about the abuse.
- Williams was convicted on several counts; the trial court and the State argued Curry limits on other-acts evidence should not bar plan/motive evidence under 404(B).
- The Eighth District reversed, holding Curry precluded admissibility of plan evidence unless it showed background or identity, and remanded.
- The Supreme Court reinstated the trial court judgment, holding 404(B) and R.C. 2945.59 permit plan/intention evidence for grooming and sexual gratification, subject to 3-step analysis and limiting instructions; it reversed the appellate court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 404(B) allows plan evidence. | State | Williams | Yes; admissible for motive/preparation/plan under 404(B) and 2945.59. |
| Whether Curry precludes plan evidence under 404(B). | State | Williams | No; Curry does not bar plan evidence under 404(B). |
| Whether the three-step test governs admission of other-acts evidence. | State | Williams | Yes; use the 3-step analysis (relevance, legitimate purpose, balancing). |
| Whether limiting instructions cure potential prejudice. | State | Williams | Limiting instructions mitigate prejudice; evidence admissible for motive/plan. |
Key Cases Cited
- State v. Curry, 43 Ohio St.2d 66 (Ohio 1975) (defines scheme/plan evidence limitations relative to background and identity)
- State v. Broom, 40 Ohio St.3d 277 (Ohio 1988) (codifies 2945.59; limits other-acts to relevant purposes)
- State v. Lowe, 69 Ohio St.3d 527 (Ohio 1994) (preclusion of character-based propensity in other-acts evidence)
- State v. Hector, 19 Ohio St.2d 167 (Ohio 1969) (relationship between 404(B) and common-law rule)
- State v. Jamison, 49 Ohio St.3d 182 (Ohio 1990) (statutory/Rule alignment with common-law exceptions)
- State v. Gamer, 74 Ohio St.3d 49 (Ohio 1995) (probative value vs. prejudice framework for other-acts)