Williams v. State

Supreme Court of Indiana
417 N.E.2d 328 (1981)

ELI5:

Rule of Law:

Evidence of a defendant's other criminal acts is admissible under the 'common scheme or plan' exception to prove identity when the method and characteristics of the crimes are so unusual and distinctive as to be like a signature.

Facts:

On December 27, 1978, a woman was attacked in her home in the middle of the night by two assailants.
One assailant wore a ski mask, while the other wore a red-hooded sweatshirt tied around his face.
The assailants gained entry by prying open the back door, used a butcher knife for intimidation, tied the victim's hands, and severed the bedroom phone wires before stealing personal property.
The victim's husband normally worked nights, and the attack had been preceded by obscene phone calls.
On January 4, 1979, just eight days later, another woman was the victim of an attack with the exact same characteristics.
This second attack was also committed by two men with the same disguises, using the same method of entry, the same weapon, and the same actions of tying the victim's hands and cutting the phone lines.
Police were led to the Defendant by an informant who suggested he might be involved in a series of 'southside' rapes.
Two of three victims identified the Defendant from a photographic array presented by police.

Procedural Posture:

An information was filed against the Defendant in trial court, charging him with burglary, robbery, and two separate counts of rape.
The Defendant filed a motion to sever the two rape charges, which the trial court granted, leading to separate trials.
During the trial for the December 27, 1978 rape, the State introduced evidence detailing the January 4, 1979 rape.
The Defendant objected to the admission of this evidence of his other alleged criminal activity.
The trial court overruled the objection and admitted the evidence.
A jury convicted the Defendant of Burglary, Robbery, and Rape.
The Defendant appealed the conviction to the Supreme Court of Indiana, which is the highest court in the state, arguing the trial court erred in admitting the evidence of the other crime.

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Issue:

Does evidence of a separate, uncharged crime become admissible to prove the defendant's identity under the 'common scheme or plan' exception when the two crimes share numerous unusual and distinctive similarities?

Opinions:

Majority - Prentice, J.

Yes. Evidence of the separate, uncharged crime is admissible because the method used was so unusual and distinctive as to constitute a 'signature.' The general rule excludes evidence of an accused's other crimes to prevent conviction based on character rather than evidence. However, an exception for a 'common scheme or plan' or modus operandi applies when the evidence is used to prove identity. This exception requires more than mere repetition of similar crimes; the method must be unique. Here, the court identified eleven specific, distinctive similarities between the charged rape on December 27 and the uncharged rape on January 4, including the assailants' disguises, the middle-of-the-night obscene phone calls, the method of entry, the use of a butcher knife, severing phone lines, and the victims' husbands working nights. Because of these numerous and striking similarities and their proximity in time, the evidence of the second crime was highly relevant to identifying the perpetrator of the first, satisfying the stringent standard for admissibility.

Analysis:

This decision reaffirms and illustrates the high standard for admitting evidence of other crimes under the modus operandi or 'signature crime' exception. It clarifies that the similarities between the charged and uncharged offenses must be numerous and distinctive, not merely superficial. The case serves as a key example for future courts in evaluating whether the probative value of such evidence for proving identity outweighs its potential for unfair prejudice. By providing a detailed list of what constitutes a 'signature,' the court offers clear guidance for applying this narrow exception to the general prohibition against propensity evidence.

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