Williams v. State
2016 WL 4446484, 199 So.3d 424, 2016 Fla. App. LEXIS 12736 (2016)
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Rule of Law:
Evidence of a defendant's flight is inadmissible to show consciousness of guilt if its probative value is substantially outweighed by the danger of unfair prejudice, which is likely when there is no clear nexus between the flight and the charged crime, such as when there is a significant time delay and little evidence the defendant knew they were a suspect.
Facts:
- On April 5, 2012, two armed men, one later identified as Fabian Williams, confronted Myron Stokes and Michael Gilbert outside Stokes' home.
- Williams demanded money from Stokes, threatened him, and ordered both victims to the ground before taking cash from Stokes' wallet.
- Unsatisfied with the amount, Williams forced Stokes at gunpoint back into the house to get more money.
- Inside, they encountered Stokes' cousin, Eugene Ghent, who was walking out. Williams pointed his gun at Ghent to prevent him from leaving.
- Ghent recognized Williams from his childhood, calling him by name, which caused Williams to hesitate.
- Ghent grabbed the gun and pushed Williams outside, where Williams tripped and dropped the weapon.
- As Ghent fled, he saw Williams' accomplice standing over Gilbert; Ghent then heard gunshots as he ran away.
- Michael Gilbert was found shot multiple times and died at the scene. Both Stokes and Ghent identified Williams to the police.
- Police attempted to locate Williams at his home and his girlfriend's home the next morning without success.
- On June 4, 2013, over a year later, Williams was found and arrested in Sylvester, Georgia.
Procedural Posture:
- The State charged Fabian Williams with robbery with a firearm, felony murder, and two counts of attempted robbery with a firearm in a Florida trial court.
- Before trial, Williams filed a motion in limine to exclude evidence of his subsequent arrest in Georgia, which the trial court denied.
- During trial, Williams moved for a judgment of acquittal on the charge of attempted robbery of Ghent, which the trial court also denied.
- A jury convicted Williams on all counts.
- The trial court sentenced Williams to life in prison for murder and robbery, and to concurrent fifteen-year terms for the attempted robberies.
- Williams (appellant) appealed his judgment and sentences to the District Court of Appeal of Florida (appellee), arguing the trial court made errors in its rulings.
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Issue:
Is evidence of a defendant's presence in another state, discovered fourteen months after a crime was committed, admissible as 'flight' evidence to prove consciousness of guilt when there is minimal proof that the defendant was aware of being a suspect at the time he left?
Opinions:
Majority - Silberman, Judge
No, evidence of a defendant's presence in another state discovered fourteen months after a crime is not admissible as 'flight' evidence without a sufficient nexus linking the departure to the specific crime charged. The court held that the probative value of flight evidence is weakened by three factors, all present here: (1) there was little evidence from which to infer Williams knew he was a suspect at the time he left for Georgia; (2) there were no clear indications of flight, merely an absence and later arrest in another state; and (3) the fourteen-month delay between the crime and his discovery was too significant. The court concluded that under the totality of the circumstances, the evidence was more prejudicial than probative and its admission was a reversible error, as it could have contributed to the verdict. The court also reversed the conviction for the attempted robbery of Ghent, finding the evidence was insufficient to prove Williams intended to take property from Ghent, as his actions only indicated an intent to prevent Ghent from leaving.
Analysis:
This decision reinforces the evidentiary standard for admitting 'flight' evidence as proof of consciousness of guilt in Florida. It clarifies that a defendant's mere absence, even culminating in an out-of-state arrest, is insufficient without a demonstrable nexus to the crime in question. The court's focus on the significant time delay and the lack of evidence that the defendant knew he was a suspect establishes a high bar for prosecutors. This precedent protects defendants from prejudicial inferences drawn from ambiguous post-crime conduct and forces the state to provide more direct evidence linking a defendant's departure to the specific crime charged.
