Justia Florida Supreme Court Opinion Summaries

Michael A. Tanzi was sentenced to death for the murder of Janet Acosta. On March 10, 2025, Governor Ron DeSantis signed a death warrant scheduling Tanzi’s execution for April 8, 2025. Tanzi sought relief in the circuit court, which was denied, leading to his appeal to the Supreme Court of Florida.The circuit court had previously denied Tanzi’s first motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, and the Florida Supreme Court affirmed this denial. Tanzi’s petition for state habeas relief was also denied. He then sought federal habeas relief, which was denied by the district court and affirmed by the Eleventh Circuit. Tanzi’s subsequent motion for postconviction relief under Hurst v. Florida was denied by the Florida Supreme Court, which found the Hurst error in his case harmless beyond a reasonable doubt.The Supreme Court of Florida reviewed Tanzi’s appeal of the denial of his third motion for postconviction relief, which raised claims about due process violations due to the compressed warrant period, the constitutionality of Florida’s lethal injection protocols, and the Governor’s authority in determining the timing of death warrants. The court affirmed the circuit court’s summary denial of these claims, finding them either procedurally barred or without merit. The court also denied Tanzi’s habeas petition, which argued that his death sentence was unconstitutional under Erlinger v. United States, and dismissed his emergency petition to invoke the court’s all writs jurisdiction.The Supreme Court of Florida held that the warrant litigation schedule did not violate Tanzi’s due process rights, the denial of public records requests was not an abuse of discretion, and the lethal injection protocol did not constitute cruel and unusual punishment. The court also upheld the Governor’s authority in signing death warrants and found no merit in Tanzi’s habeas petition. The court denied all of Tanzi’s motions and requests, including a stay of execution. View "Tanzi v. State" on Justia Law

Kevin Vericker published an internet blog questioning the credentials, character, and competency of Norman Christopher Powell, who was appointed as the attorney for North Bay Village. Powell filed a defamation lawsuit against Vericker, claiming the blog posts were defamatory per se. Vericker responded with a motion for summary judgment and an anti-SLAPP motion, arguing that Powell, as a public official, needed to prove actual malice, which he could not. The trial court denied Vericker's motion.Vericker then sought a writ of certiorari from the Third District Court of Appeal to review the denial of his anti-SLAPP motion. The Third District held that certiorari was not appropriate for reviewing such orders, aligning with the Fourth District's position that public policy favors interlocutory review through rule amendments rather than expanding certiorari jurisdiction. The Third District certified conflict with the Second District's decisions in Gundel, Baird, and Davis, which had allowed certiorari review for anti-SLAPP motions.The Supreme Court of Florida reviewed the case and held that denials of anti-SLAPP motions do not constitute irreparable harm sufficient to support certiorari relief. The court emphasized that the Anti-SLAPP statute does not provide immunity from suit but rather aims for the expeditious resolution of meritless, speech-targeted lawsuits. To align with legislative intent, the court amended Florida Rule of Appellate Procedure 9.130(a)(3) to allow interlocutory review of nonfinal orders denying anti-SLAPP motions. The court approved the Third District's decision and disapproved the Second District's conflicting decisions. View "Vericker v. Powell" on Justia Law

Debbie Mayfield, a former member of the Florida House of Representatives and Florida Senate, sought to run in a special election for Senate District 19 after the incumbent announced his resignation. Mayfield submitted the necessary paperwork to qualify for the ballot, but the Secretary of State and Director of the Division of Elections refused to place her on the ballot, citing a constitutional provision on term limits.The Circuit Court did not review the case. Mayfield directly petitioned the Supreme Court of Florida for writs of mandamus and quo warranto, arguing that the Secretary misinterpreted his authority and failed to fulfill his statutory duty.The Supreme Court of Florida reviewed the case and granted Mayfield's petition for mandamus relief. The court held that Mayfield had a clear legal right to appear on the ballot, as she had met all statutory requirements for qualification. The court found that the Secretary's role in reviewing candidate qualifications is ministerial and does not include the authority to assess a candidate's constitutional eligibility. The court also rejected the Secretary's interpretation of the term-limits provision, concluding that Mayfield's break in service meant she had not served more than eight consecutive years in the Senate. The court ordered the Secretary to place Mayfield on the ballot by a specified deadline and denied the petition for quo warranto as moot. View "Mayfield v. Secretary, Florida Department of State" on Justia Law

James D. Ford was convicted of the 1997 murders of Greg and Kimberly Malnory at a sod farm in South Florida. Ford, who worked with Greg, had planned to go fishing with the couple. Greg was shot in the head, beaten, and had his throat slit. Kimberly was raped, beaten, and shot. Their young daughter was found nearby, unharmed but exposed to the elements. Ford was convicted of two counts of first-degree murder, sexual battery with a firearm, and child abuse, and was sentenced to death.Ford's convictions and sentences were affirmed on direct appeal, and the U.S. Supreme Court denied certiorari in 2002. Ford has since filed multiple unsuccessful postconviction relief motions in state and federal courts. His third successive motion for postconviction relief, filed under Florida Rule of Criminal Procedure 3.851, was summarily denied by the circuit court. This motion raised claims that his death sentence was unconstitutional under Roper v. Simmons due to his mental and developmental age and that executing him would violate his rights under the Fifth, Sixth, Eighth, and Fourteenth Amendments in light of Erlinger v. United States.The Supreme Court of Florida reviewed the case and affirmed the circuit court's denial. The court held that Ford's claim regarding his mental and developmental age was untimely and without merit, as Roper does not extend to individuals over eighteen, regardless of mental age. The court also found that Erlinger, which involved the federal Armed Career Criminal Act, was not applicable to Ford's case. Additionally, the court rejected Ford's arguments related to Hurst v. Florida and Hurst v. State, noting that these decisions do not apply retroactively to Ford's case. The court concluded that Ford's claims were procedurally barred and meritless, and affirmed the denial of his third successive motion for postconviction relief. View "Ford v. State" on Justia Law

Matthew Lee Caylor was convicted of the 2008 first-degree murder, sexual battery, and aggravated child abuse of thirteen-year-old Melinda Hinson. Caylor, who was on the run from felony probation in Georgia for molesting a fourteen-year-old girl, committed the crimes at the Valu-Lodge Motel in Panama City, where Melinda was living with her family. Caylor confessed to the crimes, stating he murdered Melinda to avoid arrest and out of anger from his previous conviction. Physical and DNA evidence corroborated his confession.The jury convicted Caylor and recommended the death penalty by an eight to four vote. The Florida Supreme Court affirmed the convictions and sentences on direct appeal but granted a new penalty phase due to the nonunanimous jury recommendation, pursuant to Hurst v. State. During the new penalty phase, Caylor vacillated on waiving his rights to a jury, mitigation evidence, and his presence. Ultimately, he waived these rights, primarily to spare the victim’s family a lengthy process. The trial court accepted his waivers after a full colloquy.The Florida Supreme Court reviewed the case and affirmed the trial court's decisions. The court found that Caylor's post-penalty phase request to withdraw his jury waiver was untimely and made in bad faith to delay proceedings. The court also rejected Caylor's argument that his waiver was based on misinformation about the victim's mother's death, stating that his understanding of his rights at the time of the waiver was not affected by this information. Additionally, the court found no error in the trial court's handling of the mitigation waiver and upheld the trial court's findings on the aggravating factors. The Florida Supreme Court concluded that the aggravators outweighed the mitigators and affirmed Caylor's death sentence. View "Caylor v. State" on Justia Law

Robert Craft, a prisoner sentenced to death, appealed the circuit court's denial of his initial motion for postconviction relief under Florida Rule of Criminal Procedure 3.851. Craft was convicted of premeditated first-degree murder for strangling and beating to death his cellmate, Darren W. Shira, at Columbia Correctional Institution on May 16, 2018. Craft confessed multiple times and provided detailed accounts of the murder, including his premeditation and the methods he used. He was indicted on October 1, 2018, and expressed a desire to plead guilty and receive the death penalty. After being found competent to represent himself, Craft pled guilty and waived his right to a penalty-phase jury and mitigation.The trial court accepted Craft's guilty plea and sentenced him to death. The Florida Supreme Court affirmed his conviction and sentence on direct appeal. Craft then filed a motion to vacate his conviction and sentence on six grounds, including ineffective assistance of counsel and prosecutorial misconduct. The circuit court conducted a Huff hearing and ultimately denied all of Craft's claims.The Supreme Court of Florida reviewed the circuit court's decision and affirmed the denial of postconviction relief. The court found that Craft's claims of ineffective assistance of counsel were either not cognizable or without merit, as trial counsel's performance was not deficient. The court also determined that Craft's claims of prosecutorial misconduct were procedurally barred because they could have been raised on direct appeal. Additionally, the court rejected Craft's claim of cumulative error, as each individual claim failed. The court concluded that the postconviction court did not err in summarily denying Craft's motion. View "Craft v. State of Florida" on Justia Law

In 2004, John F. Mosley was convicted of the first-degree murders of his ten-month-old son, Jay-Quan, and the boy’s mother, Lynda Wilkes. Evidence presented at Mosley’s 2005 trial established that he strangled Wilkes, asphyxiated Jay-Quan in a garbage bag, and disposed of their bodies. Wilkes’s remains were recovered, but Jay-Quan’s body was never found. Mosley received a life sentence for Wilkes’s murder and a death sentence for Jay-Quan’s murder.The Florida Supreme Court twice vacated Mosley’s death sentence, most recently in 2022, due to procedural errors, including the trial court’s failure to address Mosley’s motion to represent himself. The case was remanded for a new Spencer hearing and sentencing. Upon remand, Mosley requested counsel, and the trial court again imposed a death sentence. Mosley appealed, raising two issues.The Supreme Court of Florida reviewed the case. Mosley’s first claim, seeking a new penalty phase due to alleged jury nullification, was deemed procedurally barred as it was not raised in his previous appeal. The second claim, regarding newly discovered evidence of the medical examiner’s impairment, was dismissed as untimely. The court noted that even if the claim were timely, it would not succeed because the evidence was not likely to produce an acquittal on retrial.The Supreme Court of Florida affirmed Mosley’s death sentence, concluding that the issues raised were not properly before the court and did not warrant relief. View "Mosley v. State" on Justia Law

The case involves the review of final orders by the Public Service Commission (PSC) approving proposals from four electric utility companies to enhance the power grid's resilience against extreme weather. These proposals were submitted under section 366.96, Florida Statutes, enacted in 2019. The Office of Public Counsel (OPC) challenged the PSC's orders, arguing that the PSC misinterpreted the statute and compromised the fairness of the proceedings by striking portions of an expert's testimony.Previously, the PSC approved the initial Storm Protection Plans (SPPs) submitted by the utilities in 2020, following settlements that allowed for future challenges to the prudence of the projects. In 2022, the utilities submitted updated SPPs for the 2023-2032 period. The PSC issued final orders approving the SPPs, with some modifications, and the OPC appealed these orders.The Supreme Court of Florida reviewed the case and held that the PSC correctly interpreted the statute and acted within its authority. The Court found that the PSC's determination of the public interest did not require a prudence review of the SPPs at the plan approval stage. Instead, the prudence review is to be conducted during the cost recovery proceedings. The Court also held that the PSC did not abuse its discretion in striking the expert testimony, as it contained impermissible legal opinions.The Supreme Court of Florida affirmed the PSC's final orders, concluding that the PSC properly considered the statutory factors and provided adequate support for its public interest determination. The Court also found that the exclusion of the expert testimony did not impair the fairness of the proceedings. View "Citizens of the State of Florida v. Fay" on Justia Law

The case involves a claim by Mitchell against Race under the Florida Security of Communications Act, which prohibits recording phone calls without the consent of all parties. Mitchell alleged that Race, while out of state, recorded phone calls with him, a Florida resident, without his consent. The central issue was whether Florida courts have personal jurisdiction over Race, a nonresident defendant.The trial court focused on whether Race committed a tortious act in Florida, concluding that he did because the interceptions occurred where Mitchell's statements were made. The court also found that exercising personal jurisdiction over Race did not violate due process. On appeal, the Fourth District Court of Appeal reversed the trial court's decision, concluding that Race lacked sufficient minimum contacts with Florida to justify personal jurisdiction. The Fourth District did not address whether Race committed a tortious act in Florida but certified conflict with a previous case, France v. France, which addressed the first step of the jurisdictional test.The Supreme Court of Florida initially accepted jurisdiction to resolve the certified conflict. However, after further consideration, the court concluded that the conflict was not clear and that the record was insufficient to address the due process issue analyzed by the Fourth District. Consequently, the Supreme Court of Florida decided to discharge jurisdiction and dismiss the proceeding, determining that the issues presented were largely academic given the unique procedural history of the case. View "Mitchell v. Race" on Justia Law

In 1983, Kayle Barrington Bates was convicted of kidnapping, attempted sexual battery, armed robbery, and first-degree murder of Janet White. Bates attacked White in her office, forced her into the woods, and murdered her. He was found at the crime scene with the victim’s blood on his clothing, and other physical evidence linked him to the crime. Bates gave inconsistent confessions, and the jury recommended the death penalty, which the court imposed.Bates's case has undergone multiple appeals. The Florida Supreme Court affirmed his conviction but remanded for reconsideration of the death sentence. After resentencing, Bates was again sentenced to death, which was affirmed. In 1989, the Governor signed Bates’s death warrant, but the trial court stayed his execution and ordered a new sentencing hearing due to ineffective counsel. The jury again recommended the death penalty, and the circuit court imposed it, which was affirmed by the Florida Supreme Court. Bates later petitioned for habeas corpus, raising issues about jury selection, but relief was denied.Bates recently sought to interview a juror from his 1983 trial, claiming to have learned that the juror was related to the victim’s family. The postconviction court denied his motion under Florida Rule of Criminal Procedure 3.575, which requires such motions to be filed within 10 days of the verdict unless good cause is shown. Bates did not specify when he discovered the relationship, failing to establish good cause for the delay.The Supreme Court of Florida affirmed the postconviction court’s denial, holding that Bates did not meet the burden of showing good cause for the 40-year delay in seeking the juror interview. The court emphasized the importance of timely motions to ensure that facts are fresh and readily ascertainable. View "Bates v. State" on Justia Law