Jackson v. State
The Fifth District affirmed a first-degree murder and sexual battery conviction, holding the trial court did not abuse its discretion in admitting collateral-crime evidence of the defendant's 1986 sexual battery under section 90.404(2)(c), Florida's sexual-propensity evidence statute. The court applied the McLean similarity/time/frequency/intervening-circumstances factors and found the evidence properly admitted despite a roughly two-decade gap between offenses.
Key facts
- Defendant Jackson was convicted in trial court of first-degree murder and sexual battery.
- The State introduced evidence of defendant's 1986 sexual battery conviction, approximately two decades before the charged offenses, under Florida's sexual-propensity evidence statute.
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Why it matters
This opinion offers a useful, citable application of the McLean factors for Williams-rule/sexual-propensity evidence under section 90.404(2)(c), particularly its treatment of intervening incarceration as substantially… — full analysis with a trial
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