Florida Court Discusses Introduction of Collateral Crime Evidence in Criminal Cases

When a person is charged with a crime in Florida, the State is generally precluded from introducing collateral evidence of other crimes. In other words, the State cannot produce evidence of uncharged crimes that the defendant allegedly committed as evidence of the defendant’s guilt. There are certain situations in which collateral crime evidence is admissible, however, as demonstrated in a recent Florida appellate court case, in which the defendant was charged with kidnapping. If you are a resident of Sarasota charged with kidnapping or another violent crime, it is in your best interest to speak with a knowledgeable Sarasota violent crime defense attorney to discuss the evidence that the State may be permitted to introduce against you at trial.

Evidence Produced at the Defendant’s Trial

The defendant was charged with eight crimes, including sexual battery, unlawful imprisonment, rape, and kidnapping. The case proceeded to trial, during which the State introduced evidence of crimes with which the defendant was not charged but that the State alleged he committed. The defendant was convicted, after which he appealed, arguing the trial court erred in permitting the State to introduce collateral crime evidence.

Collateral Crime Evidence in Florida Criminal Matters

On appeal, the defendant argued that the State introduced evidence of the defendant’s alleged collateral crimes to impugn his character and that allowing such evidence denied him of the right to a fair trial. Specifically, during the trial, the defendant’s alleged victim, who was his former girlfriend, testified that the defendant tortured her for hours. The defendant argued that such testimony was improper because it introduced evidence of acts that were not part of the crimes with which the defendant was charged.

The court rejected the defendant’s argument for multiple reasons. First, the court found that evidence introduced at trial regarding the uncharged criminal acts allegedly committed by the defendant was inextricably linked with the evidence of the charged crimes. The court stated that under Florida law, collateral crime evidence is inextricably linked with a crime if it is essential to sufficiently describe the crime, to provide an understandable account of the charged crime or the context out of which the crime arose, or to sufficiently describe the events leading up to the crime.

In the subject case, the victim testified about numerous uncharged batteries and assaults that were interwoven with the charged offenses. Thus, the court found the trial court did not commit an error in admitting the evidence. Furthermore, the court stated that the evidence of the uncharged crimes was relevant because it established elements of the kidnapping charge against the defendant, and therefore it did not constitute collateral crime evidence. Specifically, it established that the defendant intended to terrorize or harm the victim. As a result, the court affirmed the trial court ruling.

Consult a Diligent Sarasota Defense Attorney

If you are charged with committing a violent crime in Sarasota, it is critical to speak with a trusted Sarasota attorney to discuss your case and the defenses that you may be able to set forth to protect your rights. Attorney William Hanlon at Hanlon Law is a dedicated Sarasota criminal defense attorney who can develop compelling arguments on your behalf to help you seek a successful result. You can contact Mr. Hanlon at 941-462-1789 to schedule a confidential and free meeting.

Badges