Santiago v. State

Ivan Santiago appeals his conviction for possession of cocaine, a lesser-included offense of the charge of trafficking in cocaine. He argues that the trial court erred in denying his motion for judgment of acquittal on the trafficking charge and in admitting Williams rule evidence of a prior drug sale. We affirm as to both points on appeal.

Before trial, the state filed a motion to introduce evidence of the defendant’s sale of cocaine to an undercover officer two weeks before events that led to the drug trafficking charge. At the hearing on the Williams Rule evidence, an undercover officer for…