People v. Williams, 69 N.Y.2d 951 (1987)
Evidence that a defendant did not participate in an uncharged crime is generally inadmissible to demonstrate a lack of predisposition to commit the charged crime.
Summary
The New York Court of Appeals affirmed the defendant’s conviction for criminal sale of a controlled substance. The defendant argued that a preclusion order preventing him from cross-examining witnesses about a co-defendant’s subsequent drug sale violated his Sixth Amendment rights. The Court of Appeals held that evidence of the defendant’s non-participation in the subsequent sale, offered to show a lack of predisposition to commit the charged crime, was irrelevant and inadmissible. The court reasoned that just as prior bad acts are inadmissible to show predisposition, the absence of bad acts is equally inadmissible to show lack of predisposition.
Facts
The defendant, Williams, along with co-defendants Arrington and Perkins, were charged with selling approximately 33 grams of heroin to an undercover officer on September 16, 1982. Arrington was separately indicted for selling a larger quantity of heroin on September 27, 1982. At trial, witnesses identified Williams as the “boss” of the operation. Williams sought to portray himself as an innocent bystander.
Procedural History
Arrington moved for a severance, fearing testimony about his September 27 sale would prejudice him, arguing it was inadmissible under People v. Molineux. Williams joined the motion. The trial court denied the severance but granted Arrington’s alternative motion to preclude the prosecution and co-defendants from referring to the September 27 transaction. Both Arrington and Williams were convicted. Williams appealed, arguing the preclusion order violated his Sixth Amendment confrontation rights.
Issue(s)
Whether the trial court erred in precluding the defendant from introducing evidence that he was not involved in a subsequent drug sale by a co-defendant to rebut the prosecution’s argument that he was the “boss” of the drug operation and therefore likely to be involved in the charged crime.
Holding
No, because evidence of the defendant’s non-participation in the subsequent sale, offered solely to show he was not predisposed to commit the charged crime, was irrelevant and inadmissible.
Court’s Reasoning
The Court of Appeals reasoned that the evidence Williams sought to introduce was irrelevant to the charges against him. The court stated, “[j]ust as evidence of prior criminal conduct cannot be admitted as evidence-in-chief to establish a predisposition to commit the crime charged… evidence tending to establish that a defendant did not commit uncharged crimes is, because of its irrelevancy, similarly inadmissible as evidence-in-chief to establish that the defendant did not commit the charged crime” (People v. Johnson, 47 NY2d 785, 786). The court emphasized that Williams was trying to use the lack of involvement in the subsequent sale to suggest he was not predisposed to commit the charged crime. The court found that the preclusion order was proper and did not violate Williams’ Sixth Amendment right of confrontation. The court essentially applied a principle of symmetry: if prior bad acts are inadmissible to show a propensity to commit crimes (absent specific exceptions under Molineux), then the absence of bad acts is equally inadmissible to prove a lack of propensity. This highlights the importance of focusing on evidence directly related to the elements of the charged crime rather than general character evidence.