State v. Williams, No. 64470
| Court | United States State Supreme Court of Florida |
| Writing for the Court | PER CURIAM; BOYD |
| Citation | 453 So.2d 824 |
| Decision Date | 26 July 1984 |
| Docket Number | No. 64470 |
| Parties | STATE of Florida, Petitioner, v. Willie WILLIAMS, Respondent. |
Page 824
v.
Willie WILLIAMS, Respondent.
Jim Smith, Atty. Gen. and Wallace E. Allbritton, Asst. Atty. Gen., Tallahassee, for petitioner.
Michael E. Allen, Public Defender and Paula S. Saunders, Asst. Public Defender, Second Judicial Circuit, Tallahassee, for respondent.
PER CURIAM.
This cause is before us pursuant to a certified question of great public importance from the First District Court of Appeal. Williams v. State, 439 So.2d 1014 (Fla. 1st DCA 1983). We have jurisdiction. Art. V, § 3(b)(4), Fla. Const.
Respondent was charged, in nine separate informations, with burglary and theft occurring on eight different days, 1 involving nine different victims, and, in two additional informations, with thefts involving the same victim on the same day. The state's motion to consolidate was granted without explanation. The jury found respondent guilty as charged.
The district court reversed on the authority of Paul v. State, 385 So.2d 1371 (Fla.1980). In Paul, this Court adopted Judge Smith's dissent relating to Florida Rule of
Page 825
Criminal Procedure 3.151 2 and the consolidation of related offenses. Paul v. State, 365 So.2d 1063, 1065 (Fla. 1st DCA 1979) (Smith, J., dissenting). We held in Paul that consolidation is improper when "based on similar but separate episodes, separated in time, which are 'connected' only by similar circumstances and the accused's alleged guilt in both or all instances." 365 So.2d at 1065-66, adopted 385 So.2d at 1372. The purpose of requiring separate trials under these circumstances is "to assure that evidence adduced on one charge will not be misused to dispel doubts on the other...." 365 So.2d at 1066, adopted 385 So.2d at 1372. The district court correctly concluded that the offenses charged in the present case that occurred on different days and involved separate episodes were not related under Paul for purposes of consolidation. Nonetheless, the district court certified as a question of great public importance the issue of "the continued viability and applicability of the Paul ruling in this case." Williams v. State, 439 So.2d at 1016. The district court was concerned that "strict adherence to Paul necessarily results in further imposition on our already overburdened trial courts." Id. at 1015-16. However, as we have previously stated,[e]ven if consolidation is the "most practical and efficient method of...
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26 practice notes
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Boyd v. State, No. 88-1093
...not connected in an episodic sense. Moreover, we held in Jones v. State, 497 So.2d 1268 (Fla.3d DCA 1986), relying on State v. Williams, 453 So.2d 824 (Fla.1984), rev. denied, 506 So.2d 1043, cert. denied, 484 U.S. 823, 108 S.Ct. 87, 98 L.Ed.2d 48 (1987), that consolidation of offenses for ......
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Bretherick v. State, No. SC13–2312.
...expense, and judicial economy do not outweigh the defendant's right to a fair determination of guilt or innocence. See State v. Williams, 453 So.2d 824, 825 (Fla.1984). However, the defendant's opportunity for a fair determination of guilt or innocence is not diminished by placing upon him ......
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Agrofollajes, S.A. v. E.I. Du Pont De Nemours & Company, Inc., No. 3D07-2322 (Fla. App. 12/16/2009), No. 3D07-2322.
...to it. Unfair prejudice resulting from consolidation is a broadly recognized principle. The Florida Supreme Court in State v. Williams, 453 So. 2d 824, 825 (Fla. 1984), held that "even if consolidation is the `most practical and efficient method of processing' a case, practicality and effic......
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Jones v. State, No. 86-67
...and for separate trials of Page 1272 the charges which arose from the two criminal episodes. The supreme court held in State v. Williams, 453 So.2d 824, 825 (Fla.1984) (citing Paul v. State, 365 So.2d 1063, 1065 (Fla. 1st DCA 1979) (Smith, J., dissenting)), "that consolidation [of offenses]......
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26 cases
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Boyd v. State, No. 88-1093
...not connected in an episodic sense. Moreover, we held in Jones v. State, 497 So.2d 1268 (Fla.3d DCA 1986), relying on State v. Williams, 453 So.2d 824 (Fla.1984), rev. denied, 506 So.2d 1043, cert. denied, 484 U.S. 823, 108 S.Ct. 87, 98 L.Ed.2d 48 (1987), that consolidation of offenses for ......
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Bretherick v. State, No. SC13–2312.
...expense, and judicial economy do not outweigh the defendant's right to a fair determination of guilt or innocence. See State v. Williams, 453 So.2d 824, 825 (Fla.1984). However, the defendant's opportunity for a fair determination of guilt or innocence is not diminished by placing upon him ......
-
Agrofollajes, S.A. v. E.I. Du Pont De Nemours & Company, Inc., No. 3D07-2322 (Fla. App. 12/16/2009), No. 3D07-2322.
...to it. Unfair prejudice resulting from consolidation is a broadly recognized principle. The Florida Supreme Court in State v. Williams, 453 So. 2d 824, 825 (Fla. 1984), held that "even if consolidation is the `most practical and efficient method of processing' a case, practicality and effic......
-
Jones v. State, No. 86-67
...and for separate trials of Page 1272 the charges which arose from the two criminal episodes. The supreme court held in State v. Williams, 453 So.2d 824, 825 (Fla.1984) (citing Paul v. State, 365 So.2d 1063, 1065 (Fla. 1st DCA 1979) (Smith, J., dissenting)), "that consolidation [of offenses]......
Request a trial to view additional results