Justia Florida Supreme Court Opinion Summaries

Ashley Brito and Jennifer Salas, a same-sex couple, sought to have a child using Angel Rivera’s sperm, which Brito used via an at-home artificial insemination kit. After Brito became pregnant, she and Salas married. The birth certificate listed both women as parents. They raised the child together for over a year before separating, with Brito taking the child. Rivera subsequently sought to be recognized as the child’s legal father.The Circuit Court denied Rivera’s petition for paternity, relying solely on section 742.14 of the Florida Statutes, which it interpreted to mean that a sperm donor—unless part of the commissioning couple or having executed a preplanned adoption agreement—automatically relinquishes all parental rights. The court determined that Rivera was a donor and did not fit either exception. The Second District Court of Appeal affirmed, concluding Rivera was “obviously the donor” and that the statute’s relinquishment provision applied irrespective of whether assisted reproductive technology (ART) was involved.The Supreme Court of Florida reviewed the case, addressing the certified conflict with Enriquez v. Velazquez, a Fifth District Court of Appeal decision holding section 742.14 only applies when a child is conceived using ART, not at-home artificial insemination. The Supreme Court held that section 742.14 applies exclusively in contexts involving ART, as defined by laboratory handling of human eggs or preembryos. Since the child in this case was not conceived through ART, Rivera’s parental rights were not automatically relinquished by operation of section 742.14. The Supreme Court quashed the Second District’s decision, disapproved A.A.B. v. B.O.C., and approved Enriquez v. Velazquez. View "Brito v. Salas" on Justia Law

Bryan Repple was arrested for driving under the influence of alcohol by a Maitland police officer in Maitland, Florida. After the arrest, the officer transported Repple to a breath test facility located outside the city limits, in Orange County, where the officer read the statutory implied consent warning and requested Repple to submit to a breath test. Repple complied, and the test revealed an illegal breath-alcohol level. The central issue in the case was whether the officer, acting outside his municipal jurisdiction when requesting the breath test, had legal authority to do so under Florida law.The matter first came before a Florida trial court, which granted Repple’s motion to suppress the breath test results, finding that the Maitland officer lacked authority to request the test outside his jurisdiction. The Sixth District Court of Appeal affirmed this suppression order, concluding that no legal basis existed for the officer’s extraterritorial action, and rejecting the State’s argument that a continuing investigation exception applied. The district court noted no evidence of a mutual aid agreement and found no statutory or judicial authorization for such extraterritorial police power. The Sixth District certified a direct conflict with a decision by the Fifth District Court of Appeal in State v. Torres, which had held that a municipal officer could request a breath test outside his jurisdiction as part of a continuing DUI investigation.The Supreme Court of Florida reviewed the case based on the certified conflict. It held that, under Florida’s implied consent law, a municipal police officer who makes a DUI arrest within his jurisdiction is implicitly authorized to request a breath test outside his jurisdiction when necessary to complete the statutory process. The Court quashed the Sixth District’s decision in Repple and approved the result in Torres, clarifying that the officer’s authority arose by necessary implication from the statute. View "State v. Repple" on Justia Law

Florida PACE Funding Agency initiated a proceeding in the Second Judicial Circuit to validate the issuance of $5 billion in bonds for financing certain property improvements under the PACE Act. The agency complied with statutory notice requirements, and a hearing was held where State Attorneys from the Second, Seventh, and Ninth Circuits were represented. No party objected to the entry of final judgment validating the bonds, and the judgment became final without any appeal. Over a year later, various governmental entities—including state attorneys, counties, and tax collectors (most of whom did not participate in the original proceedings)—filed motions under Florida Rule of Civil Procedure 1.540, seeking relief from the judgment, raising arguments such as lack of jurisdiction, due process violations, and alleged surprise.The circuit court allowed discovery and held an evidentiary hearing, after which it denied all motions for relief from judgment. For the parties who had not appeared previously, the court found that rule 1.540 did not apply to bond validation judgments due to the strict finality requirements of chapter 75, Florida Statutes, and that the motions were untimely and insufficient. For the state attorneys who had participated, the court concluded they were procedurally barred from seeking relief under rule 1.540 because it could not substitute for appellate review.On appeal, the Supreme Court of Florida reviewed whether rule 1.540 applies to final judgments in bond validation proceedings under chapter 75. The court held that chapter 75’s finality language—specifically section 75.09—precludes the use of rule 1.540 to collaterally attack such judgments after the time for appeal has expired. The court concluded that the statutory scheme is exclusive, and the rules of civil procedure do not override the statute. Accordingly, the Supreme Court of Florida affirmed the circuit court’s denial of the motions for relief from judgment. View "State Attorneys for the Second, Seventh and Ninth Judicial Circuits v. Florida Pace Funding Agency" on Justia Law

A woman against whom a default judgment had been entered later married and, after her marriage, her husband opened a bank account solely in his name. Some months later, both spouses executed new signature cards for the account, designating ownership as “tenancy by the entireties” and checking the relevant box. The husband’s wages were the only funds deposited into the account. When the creditor holding the judgment against the wife sought to garnish the account, she asserted that the account was exempt from garnishment as an entireties account, since the debt was her individual obligation.The Circuit Court rejected her claim of exemption, holding that because the account was originally opened by only one spouse, the common law “unities” of time and title were not present, and the account could not be a tenancy by the entireties. The petitioner did not dispute the absence of these unities but argued that the express designation on the signature card and section 655.79(1), Florida Statutes, made the account an entireties account regardless. The Second District Court of Appeal affirmed the trial court’s decision, holding that neither the Florida Supreme Court’s decision in Beal Bank, SSB v. Almand & Associates nor section 655.79(1) eliminated the common law requirements for an entireties account. The Second District certified conflict with the Fourth District’s decision in Versace v. Uruven, LLC, which had found a similar account exempt.The Supreme Court of Florida reviewed the case to resolve the conflict. It held that while Beal Bank did not address or eliminate the common law unities for entireties accounts, the 2008 amendment to section 655.79(1) did. The Court concluded that under the statute, a joint spousal account may be held as a tenancy by the entireties even if originally opened by only one spouse. The Court quashed the Second District’s decision and approved Versace to the extent it was consistent. View "Loumpos v. Bank One" on Justia Law

In 2010, a woman was found dead in her Jacksonville, Florida apartment, having been stabbed approximately ninety times. The investigation led law enforcement to question the defendant, who initially denied involvement but ultimately confessed to the killing and to taking items from the apartment. He was charged with first-degree murder. At trial in Duval County, a jury found him guilty, and after a penalty-phase proceeding where the defendant declined to present additional mitigating evidence, the jury unanimously recommended a death sentence. The trial court imposed the death penalty, finding the aggravating factors outweighed the mitigating circumstances.The Florida Supreme Court previously affirmed his conviction and sentence on direct appeal. Subsequent challenges included an initial postconviction motion, a state habeas petition, and a first successive postconviction motion, all of which were denied. While the first successive motion was pending, the defendant filed a second successive postconviction motion in the state circuit court, raising new constitutional claims related to the representativeness of his jury. He relied on a recent academic study to argue that his jury was not drawn from a fair cross-section of the community. The circuit court summarily denied the motion as untimely and meritless.The Supreme Court of Florida reviewed the appeal from the circuit court’s summary denial. The court held that the claims were untimely under rule 3.851, as the academic study did not constitute newly discovered evidence. Additionally, the claims were procedurally barred because they could have been raised earlier. The court also found the Sixth, Eighth, and state constitutional claims to be legally insufficient, clarifying that the fair cross-section requirement applies to the jury pool, not the petit jury. The denial of postconviction relief was affirmed. View "David Kelsey Sparre v. State of Florida" on Justia Law

A nonprofit research foundation affiliated with a state university entered into a memorandum of understanding (MOU) with the university in 2007, becoming a statutorily regulated direct-support organization (DSO). The MOU provided that the foundation’s board would include two appointees from the university but was otherwise silent on board approval and on budget approval processes. In 2018, the Florida Legislature enacted a law requiring all DSO board appointments to be approved by the university’s board of trustees. Around the same time, a regulation by the Board of Governors (BOG) required university boards of trustees to approve DSO budgets. The foundation challenged these requirements, arguing that they impaired its contractual rights under the MOU.The Circuit Court conducted a trial and found that the MOU limited the university’s involvement to only the two appointees and that the statutory board approval requirement impaired the MOU. It concluded that the university failed to show a significant and legitimate public purpose for the statute. However, regarding the budget approval dispute, the court held that the MOU did not address budget approval, so there was no contractual impairment. The Fourth District Court of Appeal affirmed both findings, concluding that the statutory board approval requirement rewrote the parties’ contract, while the regulation on budget approval did not impair the MOU.The Supreme Court of Florida reviewed the case. It held that the MOU only addressed the university’s power to appoint two board members and was silent on approval of other appointments or on budget approval. Therefore, the statutory and regulatory changes did not impair any specific contractual obligations. The court reversed the Fourth District’s ruling on the board appointment issue and otherwise affirmed, holding that neither the statute nor the regulation unconstitutionally impaired the MOU. View "Florida Atlantic University Board of Trustees v. Harbor Branch Oceanographic Institute Foundation, Inc." on Justia Law

Juan Javier Oquendo was charged with first-degree murder following the fatal shooting of James Cason outside a bar in Pinellas County, Florida. On the night of the incident, Oquendo interacted with several individuals, including his sister and a security guard, before an altercation occurred with Cason near Cason’s car. Witnesses provided conflicting accounts regarding whether Cason or Oquendo produced a gun and how the shooting transpired. Physical evidence indicated multiple shots were fired, and Cason died from a gunshot wound to the head. After the incident, Oquendo fled and later admitted to another individual that he had shot someone. At trial, Oquendo claimed the gun discharged accidentally during a struggle, and the jury was instructed on self-defense.The Circuit Court for Pinellas County denied Oquendo’s request to present expert testimony from a psychologist regarding his post-traumatic stress disorder (PTSD), finding the evidence irrelevant to the self-defense claim and potentially confusing to the jury as diminished capacity evidence. The jury acquitted Oquendo of first-degree murder but convicted him of manslaughter with a firearm. The Second District Court of Appeal affirmed the conviction, holding that PTSD evidence was categorically irrelevant to self-defense under Florida’s objective reasonable person standard, and certified conflict with the First District Court of Appeal’s decision in State v. Mizell, which had allowed limited PTSD evidence in support of self-defense.The Supreme Court of Florida reviewed the case to resolve the conflict. It held that Florida’s self-defense standard contains both a subjective component—what the defendant actually believed—and an objective component—what a reasonably prudent person would believe. PTSD evidence may be relevant to the subjective component but not the objective one. Nevertheless, the Court found no reversible error in excluding the PTSD testimony in Oquendo’s case and approved the Second District’s affirmance of his conviction. View "Oquendo v. State of Florida" on Justia Law

In 1996, Samuel Smithers was hired to maintain a 27-acre property in Plant City, Florida, where two women, Cristy Cowan and Denise Roach, were found murdered near the property’s ponds. Evidence, including DNA and surveillance footage, linked Smithers to the victims. After being questioned by law enforcement, Smithers gave inconsistent statements and ultimately confessed to both murders. At trial, medical testimony established that both victims died from a combination of strangulation and wounds inflicted by a sharp instrument. Smithers testified in his own defense, blaming an unknown man for the crimes, but the jury convicted him of two counts of first-degree murder and unanimously recommended the death penalty for both.The Circuit Court for Hillsborough County sentenced Smithers to death, finding several aggravating factors and weighing mitigating circumstances. The Florida Supreme Court affirmed his convictions and sentences on direct appeal. Smithers subsequently filed multiple postconviction motions and federal habeas petitions, all of which were denied by the respective courts, including the United States Supreme Court’s denial of certiorari. In 2025, after the Governor signed his death warrant, Smithers filed a successive postconviction motion arguing that executing him at age 72 would constitute cruel and unusual punishment due to his advanced age.The Supreme Court of Florida reviewed the summary denial of Smithers’ motion. The court held that his claim was untimely and procedurally barred under Florida Rule of Criminal Procedure 3.851, as none of the rule’s exceptions applied. Additionally, the court concluded that Florida’s conformity clause requires its courts to follow United States Supreme Court precedent, which does not recognize a categorical exemption from execution based on advanced age. Therefore, the Supreme Court of Florida affirmed the circuit court’s summary denial of Smithers’ successive postconviction motion. View "Smithers v. State" on Justia Law

In 2009, after a history of domestic violence and threats, the defendant killed his wife and five young children by cutting their throats and then fled to Haiti, where he was apprehended and confessed. He attributed his actions to “bad spirits” and voodoo spells. Upon return to Florida, he pled guilty to six counts of first-degree murder, waived his right to a penalty-phase jury, and declined to present mitigation evidence. Throughout the proceedings, his competency to stand trial was repeatedly evaluated, with findings alternating between competent and incompetent, but ultimately he was found competent at the time of his plea and sentencing. His defense team, which included both public defenders and later court-appointed attorneys, conducted extensive mitigation investigations, including mental health and cultural background assessments, despite the defendant’s lack of cooperation.The Circuit Court for Collier County imposed six death sentences, finding multiple aggravating factors and twelve mitigating factors, including some evidence of mental illness. On direct appeal, the Supreme Court of Florida affirmed the convictions and sentences, rejecting claims regarding self-representation, aggravator duplication, and the constitutionality of the death penalty. The defendant then filed a motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, raising claims of ineffective assistance of counsel related to competency and mitigation, and challenging restrictions on access to public records. The circuit court denied all claims after an evidentiary hearing.The Supreme Court of Florida reviewed the appeal from the denial of postconviction relief and a related habeas corpus petition. The court held that claims regarding competency were procedurally barred, as they could have been raised on direct appeal, and that the defendant failed to show ineffective assistance of counsel under the Strickland standard. The court also found no abuse of discretion in the denial of public records requests and rejected the habeas petition alleging ineffective assistance of appellate counsel. The court affirmed the denial of postconviction relief and denied habeas corpus relief. View "Damas v. State of Florida" on Justia Law

In 2009, after a history of domestic violence and threats, the defendant killed his wife and five young children by cutting their throats and then fled to Haiti, where he was apprehended and confessed. He attributed his actions to “bad spirits” and voodoo spells. Upon return to Florida, he pled guilty to six counts of first-degree murder, waived his right to a penalty-phase jury, and declined to present mitigation evidence. Throughout the proceedings, his competency to stand trial was repeatedly evaluated, with findings alternating between competent and incompetent, but ultimately he was found competent at the time of his plea and sentencing. His defense team, which included both public defenders and later court-appointed attorneys, conducted extensive mitigation investigations, including mental health and cultural background assessments, despite the defendant’s lack of cooperation.The Circuit Court for Collier County imposed six death sentences, finding multiple aggravating factors and twelve mitigating factors, including some evidence of mental illness. On direct appeal, the Supreme Court of Florida affirmed the convictions and sentences, rejecting claims regarding self-representation, aggravator duplication, and the constitutionality of the death penalty. The defendant then filed a motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, raising claims of ineffective assistance of counsel regarding competency and mitigation, and challenging restrictions on access to public records. The circuit court denied all claims after an evidentiary hearing.The Supreme Court of Florida reviewed the appeal from the denial of postconviction relief and a related habeas corpus petition. The court held that claims regarding competency were procedurally barred, as they could have been raised on direct appeal, and that the defendant failed to show ineffective assistance of counsel under the Strickland standard. The court also found no abuse of discretion in the denial of public records requests and rejected the habeas petition alleging ineffective assistance of appellate counsel. The denial of postconviction relief and the habeas petition were affirmed. View "Damas v. State of Florida" on Justia Law