State v. Savino

In State v. Savino, 567 So. 2d 892 (Fla. 1990), the supreme court reiterated that the test for admissibility of all similar fact evidence is relevancy. The court further explained that the admissibility of reverse Williams rule evidence should be analyzed as if the other possible perpetrator were on trial and the State were seeking to introduce the evidence. See Savino, 567 So. 2d at 894. In Savino, the supreme court rejected the argument that the standard for similarity should be relaxed for reverse Williams rule evidence used to prove the identity of another perpetrator. The court did recognize, however, that it was less likely prejudice would occur when evidence of other crimes is sought to be introduced by a defendant. To a large degree, it is the potential for unfair prejudice that restricts what is regarded as legally relevant Williams rule evidence. Almost all Williams rule evidence can be said to be logically relevant in that human experience suggests that if a defendant has committed a crime in the past, the defendant is more likely to commit another crime of the same general sort in the future.