5D2023-0485
The Fifth DCA reversed Stafford's convictions for drug trafficking despite defense counsel's failure to object to numerous improper prosecutorial comments during opening and closing arguments. The court held that the prosecutors' misuse of properly admitted Williams rule evidence—repeatedly urging the jury to convict based on propensity rather than the limited purpose of knowledge—combined with personal opinion testimony, improper bolstering, and disparagement of the defense, collectively rose to the level of fundamental error requiring a new trial.
Key facts
- Stafford was convicted of drug trafficking in trial court based in part on Williams rule evidence admitted to show knowledge rather than propensity.
- Prosecutors repeatedly mischaracterized the properly admitted Williams rule evidence during opening and closing arguments, urging the jury to convict based on propensity, despite the court's limiting instructions.
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Why it matters
This opinion is useful to defense practitioners because it applies the fundamental error doctrine to reverse a conviction based entirely on unpreserved prosecutorial misconduct, providing a strong appellate vehicle even… — full analysis with a trial
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