Justia Florida Supreme Court Opinion Summaries

In the case at hand, a Florida prisoner, Leon Davis Jr., under sentences of death, appealed the denial of his initial motion for postconviction relief and also petitioned the Court for a writ of habeas corpus. The crimes involved in this postconviction appeal occurred on December 13, 2007, at the Headley Insurance Agency in Polk County. Davis was sentenced to death following a jury trial for committing robbery, binding two women with duct tape, pouring gasoline on them, and setting them on fire. One of the women was pregnant. The Supreme Court of Florida, after reviewing the case, affirmed the denial of postconviction relief and denied Davis’s habeas petition. The Court found that Davis had not demonstrated that his trial counsel was ineffective or that the trial court erred in not ordering a competency examination. The Court also found that Davis's habeas claim was procedurally barred because it was a repackaged version of one of his postconviction claims. View "Davis v. State" on Justia Law

This case involves American Coastal Insurance Company ("American Coastal") and San Marco Villas Condominium Association, Inc. ("San Marco"). American Coastal issued San Marco a policy covering the condominium complex against various perils, including hurricanes. When Hurricane Irma struck Marco Island, San Marco's buildings sustained damage and submitted a claim to American Coastal. After an investigation, American Coastal estimated San Marco’s losses to be $356,208.82 and paid $192,629.75, reflecting depreciation and application of policy deductibles. San Marco, however, obtained an estimate showing damages exceeding eight million dollars, leading to a disagreement over the amount of loss, which San Marco sought to resolve by invoking the appraisal provision in the policy.American Coastal refused, arguing that an appraisal was premature since its investigation was ongoing. San Marco subsequently sued American Coastal, seeking the court to compel an appraisal. American Coastal contested, arguing that appraisal was inappropriate because they had completely denied coverage based on a policy condition that voids coverage when the insured commits fraud or makes material misrepresentations about the insurance. The trial court sided with San Marco and ordered an appraisal. The Second District Court of Appeal affirmed the trial court's decision, and the Supreme Court of Florida granted review based on the certified conflict.The Supreme Court of Florida held that a trial court has discretion in determining the order in which coverage and amount-of-loss issues are resolved. It rejected American Coastal’s argument that coverage issues must be resolved before an appraisal can be ordered. The court found that the policy’s retained-rights provision contemplates appraisals occurring prior to resolution of coverage issues. Therefore, the court approved the decision of the Second District Court of Appeal and disapproved the certified conflict cases to the extent they are inconsistent with this opinion. View "American Coastal Insurance Company v. San Marco Villas Condominium Association, Inc." on Justia Law

In 2024, the Supreme Court of Florida heard an appeal from Paul Glen Everett, a prisoner sentenced to death for first-degree murder, burglary, and sexual battery. Everett sought to have DNA testing conducted on 15 items that he claimed were linked to an acquaintance, Jared Farmer, potentially implicating Farmer in the crimes for which Everett was convicted. He argued that such testing could potentially result in his acquittal or a finding of guilt on a lesser offense. The circuit court denied Everett's motion, and Everett appealed that decision.Upon review, the Supreme Court affirmed the lower court's denial. The court found that Everett's motion did not meet the requirements set by Florida law, which necessitates a claim that the requested DNA testing "will exonerate the" defendant or "will mitigate the sentence." The Supreme Court also noted that Everett had confessed to the crimes, and his identity as the perpetrator was not in genuine dispute during his trial. The court rejected Everett's attempt to introduce new claims that his confession was false and that Farmer was involved in the crime. Even if DNA testing had shown Farmer's involvement, the court concluded there was no reasonable probability that Everett would have received a lesser sentence given the severity of his own admitted involvement. View "Everett v. State" on Justia Law

The Supreme Court of Florida heard a case involving an appeal by James Seadler against Marina Bay Resort Condominium Association, Inc. following an injury Seadler sustained when a pool chair at the resort collapsed. The case revolved around the jury selection process during the initial trial and specifically, the denial by the trial court of Seadler’s request to dismiss a potential juror (Juror 16) for cause. Seadler argued that this decision by the trial court led to an unfair trial as he was forced to use his peremptory challenges to exclude Juror 16, leaving him without a challenge to exclude another juror (Juror 22), who he found objectionable. The First District Court of Appeal rejected Seadler's claim that an error by the trial court in denying his cause challenge to a potential juror automatically entitled him to a new trial. The Supreme Court of Florida agreed with the First District Court that the harmless error standard applies in such cases, rather than automatic entitlement to a new trial. However, the Supreme Court found that Marina Bay did not demonstrate beyond a reasonable doubt that the error by the trial court did not contribute to the verdict. The court concluded that Seadler was entitled to a new trial and quashed the decision of the First District Court. View "Seadler v. Marina Bay Resort Condominium Association, Inc." on Justia Law

In this case, the Supreme Court of Florida denied a petition brought forward by Leonard P. Gonzalez, Jr., who requested a review of a nonfinal order by the circuit court. Gonzalez was convicted of home-invasion robbery and two counts of first-degree murder, for which he was sentenced to death. The circuit court set aside his death sentences, but denied any further relief. Following changes in Florida's death-penalty laws, Gonzalez sought an order declaring that the amended statute does not apply in his case, arguing against its application as unconstitutional and inconsistent with the presumption that substantive statutes apply prospectively. The circuit court disagreed and ruled that the amended statute would apply at his upcoming penalty phase.Gonzalez then petitioned the Supreme Court of Florida, invoking its all-writs authority and authority to issue writs of prohibition, arguing against the circuit court's ruling that the new statute could be lawfully applied at his upcoming penalty phase. However, the Supreme Court of Florida determined that the relief sought is not available by way of prohibition or its all-writs authority. The court concluded that the circuit court has jurisdiction to conduct the new penalty phase and that its decision to apply the new statute does not affect this jurisdiction. The court also clarified that its all-writs provision does not add appellate jurisdiction and is restricted to preserving jurisdiction that has already been invoked or to protect jurisdiction that likely will be invoked in the future. As such, Gonzalez's petition was denied. View "Gonzalez v. State of Florida" on Justia Law

The Supreme Court quashed in part the decision of the Fifth District Court of Appeal and remanded this case for resentencing proceedings, holding that the trial court committed harmful Alleyne error. See Alleyne v. United States, 470 U.S. 99, 114 (2013).During Defendant's criminal trial, the trial court made an Alleyne error and then purported to review its own decision to determine whether the Alleyne error was harmful. The Fifth District found harmful error, concluding that the only available remedy was to remand the case with instructions to resentence Defendant under a statutory provision that carried a lesser penalty. The Supreme Court upheld the Fifth District's ruling that the trial court committed harmful Alleyne error but quashed the decision to the extent it directed that only resentencing would be an appropriate remedy, holding that on remand after making an Alleyne error, a trial court is not foreclosed from empaneling a jury to make a factual determination that affects the legally-prescribed range of allowable sentences. View "State v. Manago" on Justia Law

In this case arising from two unrelated episodes in which a Tallahassee police officer used lethal force in detaining a suspect after asserting self-defense the Supreme Court held that Marsy's Law, Fla. Const. art. I, 16(b)-(e), guarantees to no victim, including a police officer, the categorical right to withhold his or her name from disclosure to the public.After the City of Tallahassee proposed to release the law enforcement officers' names to the public, the Florida Police Benevolent Association sought an emergency injunction to prevent that from happening. The trial court denied the injunction and ordered that the names of the two officers be released. The First District Court of Appeal reversed, concluding that nothing in article I, section 16 excluded police officers or other government employees from the protections granted crime victims. The Supreme Court quashed the decision of the First District, holding that Marsy's Law did not preclude the City from releasing the two police officers' names under the circumstances of this case. View "City of Tallahassee v. Fla. Police Benevolent Ass'n" on Justia Law

The Supreme Court affirmed Defendant's convictions of first-degree murder, attempted first-degree murder, aggravated assault with a deadly weapon, carjacking with a firearm, and possession of a firearm by a convicted felon and Defendant's death sentence, holding that there was no error.On appeal, Defendant raised thirteen challenges to his convictions and death sentence. The Supreme Court rejected all of Defendant's allegations of error, holding that none of Defendant's arguments on appeal were convincing and that there was sufficient evidence to support the convictions. View "Loyd v. State" on Justia Law

The Supreme Court affirmed the holding of the court of appeal that the dangerous instrumentality doctrine did not support the trial court's judgment in the underlying case, holding that the court of appeal did not err.The son of the couple in this case was driving the subject car with the permission of both parents when he injured someone. Plaintiff alleged vicarious liability against the son's parents for the son's negligent use of the car under the dangerous instrumentality doctrine. The jury found that the son was seventy-five percent at fault for the accident and that the mother was a bailee who consented to the son's use of the car on the night of the accident. The trial court entered judgment against the son and mother. The court of appeal reversed as to the mother's vicarious liability, concluding that the trial court erred in denying the mother's renewed motion for directed verdict because the jury's determination that the mother was a bailee of the car was not a basis upon which vicarious liability could be applied under the dangerous instrumentality doctrine. The Supreme Court affirmed, holding that the dangerous instrumentality doctrine did not make the mother vicariously liable. View "Emerson v. Lambert" on Justia Law

The Supreme Court affirmed the order of the trial court summarily denying Appellant's successive motion for DNA testing filed under Fla. R. Crim. P. 3.853, holding that that the trial court did not err in summarily denying Appellant's successive motion for DNA testing.Appellant was found guilty to two counts of first-degree murder and one count of second-degree murder and sentenced to death for each first-degree murder conviction. This case arose after Appellant filed a second motion requesting DNA testing. The trial court summarily denied the successive motion as procedurally barred and insufficiently pled. The Supreme Court affirmed, holding (1) Appellant's request for DNA testing was procedurally barred; and (2) even if Appellant's claim were not procedurally barred his motion still would not support relief. View "Reynolds v. State" on Justia Law