What Is the Williams Rule In Florida ?
Under the Williams rule, similar fact evidence is generally admissible, even though it reveals the commission of another crime, as long as the evidence is relevant to prove a material fact in issue, such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident. See Williams v. State, 110 So. 2d 654 (Fla. 1959).
In Peek v. State, 488 So. 2d 52 (Fla. 1986), the principal similarities were that the crimes occurred within two months of each other in the same town, both women were white females, and both women were raped. See Peek, 488 So. 2d at 55.
In Thompson v. State, 494 So. 2d 203 (Fla. 1986), the primary similarities were that both victims were approximately the same age and build, both crimes occurred near a particular church parking lot, and the defendant was having domestic problems on both occasions. See Thompson, 494 So. 2d at 204.