State v. Woodruff
The Third DCA reversed a postconviction order granting Woodruff a new trial on his sole conviction (lewd and lascivious molestation), holding that although trial counsel performed deficiently by failing to object to inadmissible Williams-rule evidence of an uncharged second shower incident, Woodruff failed to establish Strickland prejudice. The court emphasized that the jury acquitted Woodruff of the charges most closely tied to the improper collateral-crime evidence and convicted him only on the charge least connected to it, showing the jury made individualized credibility determinations rather than convicting based on propensity.
Key facts
- Woodruff was convicted of lewd and lascivious molestation in a trial where evidence of an uncharged second shower incident occurring days after the charged incident was admitted.
- Trial counsel failed to object to the second shower incident evidence, which was inadmissible propensity or Williams-rule evidence under Florida law.
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Why it matters
This opinion is useful to practitioners handling 3.850 IAC claims premised on improperly admitted Williams-rule or collateral-crime evidence, because it clarifies that the 'presumed harmful' standard applied on direct… — full analysis with a trial
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