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Criminal Procedure Keyed to Dressler
Williams v. Florida
Citation:
399 U.S. 78, 90 S.Ct. 1893, 26L.Ed.2d 446.Facts
The defendant was on trial for a robbery. He filed a motion asking to be excused from Florida’s notice-of-alibi rule. He argued that the rule violated the Fifth and Fourteenth Amendments by compelling him to be a witness against himself. The rule requires a defendant to submit to a limited form of pretrial discovery by the State whenever he intends to rely at trial on the defense of alibi. The defendant must disclose the witnesses he proposes to use to establish that defense, and the State in turn is required to notify the defendant of any witnesses it proposes to offer in rebuttal to that defense. Both sides are under a continuing duty promptly to disclose the names and addresses of additional witnesses bearing on the alibi as they become available.
The defendant’s motion was denied. He complied with the notice-of-alibi rule and gave the State the name and address of Mary Scotty. Mrs. Scotty was summoned to the office of the State Attorney on the morning of the trial, where she gave pretrial testimony. At the trial itself, Mrs. Scotty, the defendant, and the defendant’s wife all testified that the three of them had been in Mrs. Scotty’s apartment during the time of the robbery.
During the cross-examination of Mrs. Scotty, the prosecuting attorney confronted her with her earlier statement in which she had given dates and times that did not correspond with the dates and times given at trial. Mrs. Scotty adhered to her trial story, insisting that she had been mistaken in her earlier testimony. The State also offered in rebuttal the testimony of one of the officers investigating the robbery who claimed that Mrs. Scotty had asked him for directions on the afternoon in question during the time when she claimed to have been in her apartment with the defendant and his wife.
The defendant was found guilty. He appealed.
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