Similar Fact Evidence In Sex Crime Cases
In Williams v. State, 621 So. 2d 413, 416-17 (Fla. 1993), the Court discussed the admissibility of similar fact evidence in a case where the evidence was offered to refute the defendant's claim that his victims consented to sexual activity with the defendant.
This Court held that such evidence was relevant to the issue of lack of consent to the extent that it showed "a common plan or scheme." Id. at 417.
The defendant in Williams engaged in conversation with his victims about purchasing cocaine or having sex for drugs.
He then grabbed each victim from behind and dragged her to a secluded location before attempting to sexually assault her.