Steele v. State
306 Ga. App. 870
Ga. Ct. App.2010Background
- Steele was convicted of DUI less safe to drive after a jury trial.
- Officer observed Steele driving erratically at a gas station, with strong odor of alcohol, slurred speech, unsteadiness, and six clues of impairment.
- Steele declined field sobriety tests and did not consent to a breath test.
- State introduced similar transaction evidence showing a prior DUI from August 2007 to prove bent of mind and course of conduct.
- Trial court held a Williams hearing, and admitted the similar transaction evidence for bent of mind and course of conduct, finding sufficient similarity and proper purpose.
- Steele argues admission of the prior DUI violated Williams and is prejudicial; the appellate court reviews for abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of similar transaction evidence under Williams | Steele contends the court failed to properly analyze Williams requirements. | State asserts hearing and showing satisfied Williams requirements and proper purposes. | No abuse of discretion; evidence properly admitted. |
| Prejudice of similar transaction evidence in a less safe DUI case | Bent of mind and course of conduct evidence improperly prejudicial or unnecessary. | Bent of mind rationale remains valid under Wade; cannot depart from precedent. | Affirmed judgment; no reversal on this basis. |
Key Cases Cited
- Williams v. State, 261 Ga. 640, 409 S.E.2d 649 (1991) (Ga. 1991) (requirements for Uniform Superior Court Rule 31.3(B) hearing and three affirmative showings)
- Wade v. State, 295 Ga.App. 45, 670 S.E.2d 864 (2008) (Ga. App. 2008) (bent of mind rationale for similar transaction evidence)
- Duprel v. State, 301 Ga.App. 469, 687 S.E.2d 863 (2009) (Ga. App. 2009) (similarity between prior DUI and current charge supports bent of mind)
- Evans v. State, 287 Ga.App. 74, 651 S.E.2d 363 (2007) (Ga. App. 2007) (evidence logically connected to prior DUI and bent of mind)
- Gamble v. State, 283 Ga.App. 326, 641 S.E.2d 556 (2007) (Ga. App. 2007) (admissibility of similar transaction evidence for bent of mind)