Adam Cole Crenshaw v. State
The Fifth DCA affirmed most of Crenshaw's convictions for sexual battery and lewd/lascivious molestation of his daughter, upholding admission of six years of prior abuse as both inextricably intertwined and properly-noticed Williams-rule evidence, and holding that child hearsay alone can support a conviction absent recantation or direct contradiction by the victim's own testimony. The court reversed one molestation count for insufficient proof of the charged date range, and remanded because the trial court's comments suggested it applied a sufficiency (JOA) standard rather than weighing the evidence on the motion for new trial. The court also held, as a matter of statutory construction of §847.0138, that 'transmission' of harmful material is complete upon sending, without proof the minor viewed it.
Key facts
- Defendant Crenshaw was charged with sexual battery and lewd/lascivious molestation of his own daughter based on abuse occurring over six years, plus transmission of harmful material to a minor.
- The trial court admitted evidence of six years of prior uncharged sexual abuse against the same child victim and convicted Crenshaw on multiple counts based largely on the child's hearsay statements; the child did not testify at trial regarding most acts.
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Why it matters
This opinion gives practitioners a clean statement that a trial court's failure to clearly articulate that it weighed (rather than merely assessed sufficiency of) the evidence on a motion for new trial requires remand… — full analysis with a trial
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