State v. Williams
961 N.E.2d 1200
Ohio Ct. App.2011Background
- Williams was charged in 61-count indictment with multiple rape, unlawful sexual conduct with a minor, kidnapping, gross sexual imposition, and intimidation, alleged to have occurred 2008–2009 with a 14–15-year-old victim.
- State sought to admit evidence under Evid.R. 404(B) and R.C. 2945.59 of prior sexual abuse against A.B. by Williams to prove intent or a scheme.
- Williams’s counsel requested a hearing on the 404(B) motion; the trial court denied, and trial proceeded with the 404(B) evidence introduced mid-trial.
- A.B. testified of a past sexual relationship with Williams; later, J.H. testified about Williams’s molestation of him beginning in 2008.
- The trial court admitted A.B.’s testimony to show intent and to rebut defense claims Williams was not attracted to males; the court later denied mistrial requests and the jury heard the evidence.
- Williams was convicted on multiple counts and sentenced to 20 years; on appeal, the court reversed and remanded for new trial due to improper admission of 404(B) evidence and related errors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 404(B) evidence was admissible for intent. | Williams argues prior acts show intent; the state bears burden. | Williams contends prior acts were improper, prejudicial, and not probative of intent. | Trial court erred; 404(B) evidence for intent was improper. |
| Whether 404(B) evidence could show scheme/plan or identity. | State contends evidence shows Williams’s grooming scheme. | Defense argues no background or identity connection; not within Curry framework. | Not admissible under Curry as background/identity; prejudicial outweighs probative value. |
| Whether admission of 404(B) evidence and social worker testimony was prejudicial error requiring reversal. | Evidence was probative of intent/motive. | Prejudice outweighed probative value; violated Evid.R. 403/404(B). | Admission prejudicial; reversible error; remand for new trial. |
Key Cases Cited
- State v. Smith, 49 Ohio St.3d 137 (1990) (test for admissibility of extrinsic acts to show intent)
- State v. Curry, 43 Ohio St.2d 66 (1975) (scheme/plan exceptions limited to background or identity)
- Huddleston v. United States, 485 U.S. 681 (1988) (4-part test for 404(b) admissibility (proper purpose, relevance, probative value vs. prejudice, limiting instruction))
- State v. Miley, 2006-Ohio-4670 (2006) (recognizes high prejudice risk in sexual-offense other-acts evidence)
- State v. Bey, 85 Ohio St.3d 487 (1999) (admissibility for identity via behavioral fingerprint)