Ricketts v. State

The defendant was convicted of violating sections 893.135(l)(a) and 893.03(l)(c), Florida Statutes (2009). He now appeals his conviction and sentence arguing (1) that the trial court improperly admitted Williams rule evidence of empty crates found in his storage unit, which alerted a drug-sniffing K9 to the presence of marijuana, and (2) that section 893.135 is facially unconstitutional. We disagree with the defendant and hold that (1) the trial court did not abuse its discretion by admitting this Williams rule evidence because the crates were relevant to prove a continuing scheme and that…