Williams v. State
179 A.3d 1006
Md.2018Background
- In October 2015 Harold Eugene Williams was tried for multiple offenses arising from an altercation with his then‑girlfriend; a jury convicted him of second‑degree assault and acquitted on other counts.
- Williams called three character witnesses who testified to his reputation for peacefulness; on cross‑examination the State asked whether they were aware of Williams’ 1990 battery conviction.
- The trial court allowed the State to ask the character witnesses about the 1990 battery conviction; each witness said they were not aware of it and that knowing it would not change their opinion.
- Williams argued on appeal that the 1990 conviction was too remote (it predated the witnesses’ acquaintance with him by 10–19 years) and that its admission was unfairly prejudicial, especially because the charged offense involved battery.
- The Court of Special Appeals affirmed; the Court of Appeals granted certiorari and affirmed, holding the prior battery conviction was relevant to rebut character evidence and its probative value was not substantially outweighed by unfair prejudice.
Issues
| Issue | Plaintiff's Argument (Williams) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether a conviction >15 years old is irrelevant as a matter of law to rebut a character witness’s opinion | A >15‑year old conviction should be treated as irrelevant for rebuttal (argues Rule 5‑609’s 15‑year limit should apply to Rule 5‑404 rebuttal) | No bright‑line 15‑year bar applies to rebuttal under Rule 5‑404; prior conviction may be relevant regardless of age | Court declined to read a 15‑year limit into Rule 5‑404 and held the 1990 conviction was relevant |
| Whether questions revealing the 1990 conviction (which predated witnesses’ acquaintance) were irrelevant to their opinions | Conviction predates witnesses’ knowledge of Williams by a decade or more, so it cannot be probative of their 2015 impressions | A prior battery conviction is directly related to peacefulness and can make the witnesses’ opinions less probative; relevancy has a low bar | Held relevant: conviction bore on character for non‑violence and could rebut the testimony |
| Whether admission of the 1990 conviction was unfairly prejudicial (Rule 5‑403) | Probative value is minimal because witnesses might not have known of the conviction despite knowing Williams; jurors could be unfairly prejudiced because the charged conduct involved battery | Although prejudicial, the evidence’s probative value on character for peacefulness was not substantially outweighed by unfair prejudice; trial court acted within discretion | Court held admission was not an abuse of discretion; probative value outweighed the danger of unfair prejudice |
Key Cases Cited
- Alexis v. State, 437 Md. 457 (2014) (abuse of discretion standard where no reasonable person would adopt trial court’s view)
- Fuentes v. State, 454 Md. 296 (2017) (relevancy reviewed de novo; evidentiary rulings on admission reviewed for abuse of discretion)
- Watson v. State, 321 Md. 47 (1990) (prior conviction inadmissible where it bore little relation to trait at issue)
- Michelson v. United States, 335 U.S. 469 (1948) (trial court discretion to exclude inquiry into very remote rumors or misconduct)
- Ricketts v. State, 291 Md. 701 (1981) (caution where prior similar crimes may unduly prejudice jury)
- State v. Simms, 420 Md. 705 (2011) (low threshold for relevancy: evidence that has any tendency to make a consequential fact more or less probable)