In Ricketts v. State, Florida's Fourth District Court of Appeal explains the Williams rule, which allows Sunshine State prosecutors to introduce evidence that may seem unrelated to the crime for which a defendant is charged in order to show that the person knew exactly what he was doing.
Jerome Ricketts was arrested and charged with the trafficking of between 25 and 2,000 lbs of marijuana after a stash of the drug was found in a crate in a storage unit he rented under an assumed name. At trial, he sought to prevent the prosecution from entering into evidence a number of comparable, empty crates featuring similar shipping labels with addresses from California, which were also found in the storage unit and police said smelled strongly marijuana (enough, at least, to get the attention of a drug-sniffing police dog). The trial court allowed the evidence, ruling that it was relevant to prove Ricketts' knowledge of the crime.
The Fourth District affirmed the decision on appeal, finding that the evidence was admissible under the so-called Williams rule. Evidence of other crimes is general not admissible for the purpose of proving a defendant's bad moral character of propensity for wrongdoing. In Williams v. Florida, however, the state supreme court ruled in 1959 that evidence of collateral crimes is admissible for the purpose of proving things like a defendant's motive, intent, knowledge or lack of mistake.
"In determining the admissibility of collateral crime evidence, the trial court must make two determinations: (1) whether the evidence is relevant or material to some aspect of the offense being tried, and (2) whether the probative value is substantially outweighed an any prejudice," the court explained, citing its 2011 decision in Santiago v. State.
Here, the court explained that Ricketts was charged with violating section 893.135 for "unlawfully and knowingly" purchasing or possessing a certain amount of marijuana. The evidence of the other crates -presumably also used for shipping and storing the drugs - was therefore relevant to proving the "knowingly" element of the crime, according to the court. "Because knowledge is a specific element of the crime charged," the court ruled that "the evidence of the other crates was admissible Williams rule evidence because it was relevant or material to some aspect of the offense being tried, rather than used simply to prove propensity."