Justia Florida Supreme Court Opinion Summaries

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

Matthew Dettle was charged and convicted of three felonies in Florida: using a computer to solicit a child for unlawful sexual conduct, traveling to meet a minor after such solicitation, and using a two-way communications device to facilitate a felony. His conviction for the third offense was vacated. Dettle argued that his remaining two convictions violated the Double Jeopardy Clause of the U.S. Constitution, which prohibits multiple punishments for the same offense.The First District Court of Appeal found that Dettle's convictions for traveling to meet a minor and unlawful use of a two-way communications device violated double jeopardy and vacated the latter conviction. However, it affirmed his convictions for solicitation and traveling, as they were based on separate illegal acts. Dettle's convictions became final in 2017. After the Florida Supreme Court's decision in Lee v. State, which held that courts should only consider the charging document to determine double jeopardy violations, Dettle sought retroactive relief under this new rule.The Supreme Court of Florida reviewed whether the rule in Lee should apply retroactively. The court concluded that Lee does not apply retroactively to cases that were already final when it was decided. The court reasoned that the rule in Lee is procedural, not substantive, and does not meet the high bar for retroactive application under either the Witt or Teague standards. Consequently, the court affirmed the decision of the First District Court of Appeal, denying Dettle's request for postconviction relief. View "Dettle v. State of Florida" on Justia Law

The case involves Leo L. Boatman, who was convicted and sentenced to death for the first-degree premeditated murder of William L. Chapman, a fellow inmate at Florida State Prison. The murder occurred on July 5, 2019, and was captured on multiple video cameras. Boatman, along with codefendant William E. Wells, attacked Chapman with a ligature and two shanks for approximately twelve minutes while other inmates watched. Boatman blocked the door to prevent correctional officers from intervening. Boatman later explained that the murder was a result of being denied a review to be released from Close Management confinement and that Chapman had disrespected him.The trial court found Boatman guilty of premeditated first-degree murder. During the penalty phase, Boatman waived the jury, and the judge sentenced him to death. The State presented evidence of Boatman’s prior violent felonies, while the defense presented testimony about Boatman’s traumatic upbringing and mental health issues. The trial court found four aggravating factors, including that the murder was especially heinous, atrocious, or cruel (HAC) and cold, calculated, and premeditated (CCP). The court also considered and weighed mitigating factors but ultimately imposed the death sentence.The Supreme Court of Florida reviewed the case and affirmed the conviction and death sentence. The court found that the evidence was sufficient to support the conviction and that the trial court did not err in its rulings, including denying Boatman’s motion to adjudicate him incompetent to proceed, denying his motion to disqualify the judge, and denying his motion to exclude certain evidence. The court also upheld the trial court’s findings of the CCP and HAC aggravators and rejected Boatman’s arguments regarding the constitutionality of Florida’s death penalty scheme and his claim that his serious mental illness should exempt him from the death penalty. View "Boatman v. State" on Justia Law

Adam Richardson, a citizen and taxpayer, petitioned the Supreme Court of Florida for writs of quo warranto and mandamus, alleging that the Governor, Attorney General, and Secretary of the Florida Agency for Health Care Administration (AHCA) violated section 104.31, Florida Statutes, by advocating against a proposed constitutional amendment (Amendment 4) related to abortion rights. Richardson claimed that their actions, including statements on an AHCA webpage and social media, as well as participation in a public call and opinion piece, unlawfully interfered with the vote on Amendment 4.The lower courts did not review this case as it was directly brought to the Supreme Court of Florida. Richardson argued that the respondents' actions violated a statute limiting political activities of state officers and employees, which he believed should be enforced through extraordinary writs.The Supreme Court of Florida denied the petition. The court held that the writ of quo warranto is traditionally used to test the right of a person to hold an office or exercise a state-derived power, not to compel criminal prosecution or enable private enforcement of a criminal statute. The court found that Richardson's grievances were more about the merits of the respondents' actions rather than their authority to act. Additionally, the court denied the writ of mandamus, stating that Richardson did not establish a clear legal right or an indisputable legal duty on the part of the respondents, nor did he show that there was no other adequate remedy available. The court concluded that no further relief was required to complete the exercise of its jurisdiction and denied the petition without permitting a rehearing. View "Richardson v. Secretary, Florida Agency for Health Care Administration" on Justia Law

The case involves a dispute between an insurer, GEICO, and a windshield repair shop, Glassco, regarding the Florida Motor Vehicle Repair Act. From 2016 to 2019, Glassco performed nearly 1,800 windshield repairs for GEICO’s insureds, who assigned their insurance payment rights to Glassco. GEICO paid these claims at a discounted rate, leading to litigation. GEICO sought to recover payments and claimed that Glassco violated the Repair Act by not providing written estimates and other disclosures.The U.S. District Court for the Middle District of Florida ruled in favor of Glassco, concluding that GEICO did not have a private right of action under the Repair Act because it was not a "customer" as defined by the statute. The court also held that Glassco’s violations did not render its invoices void. GEICO appealed, and the U.S. Court of Appeals for the Eleventh Circuit certified two questions to the Supreme Court of Florida regarding the insurer's rights under the Repair Act.The Supreme Court of Florida answered both certified questions in the negative. First, it held that Fla. Stat. § 559.921(1) does not grant an insurance company a cause of action when a repair shop fails to provide a written repair estimate. The court emphasized that the statute defines a "customer" as the person who signs the repair estimate, and GEICO conceded it did not meet this definition.Second, the court held that the Repair Act violations do not void a repair invoice for completed windshield repairs, nor do they preclude a repair shop from being paid by an insurance company. The court noted that the statute allows for penalties and damages to be adjusted if repairs were authorized and properly performed, indicating that voiding invoices was not intended as a remedy. The court also found that subsequent amendments to the Repair Act rendered previous case law, which might have supported GEICO’s position, obsolete. View "Government Employees Insurance Company v. Glassco Inc." on Justia Law

John Sexton was convicted of the first-degree murder of Ann Parlato, a 94-year-old woman he knew from cutting her lawn. The crime was particularly brutal, involving severe physical trauma and post-mortem mutilation. A jury initially recommended the death penalty by a 10-2 vote, and the Florida Supreme Court upheld the conviction but remanded for a new penalty phase under Hurst v. Florida. On remand, Sexton waived his right to a jury, and the trial court sentenced him to death again.In the lower courts, Sexton moved for the recusal of Judge Mary Handsel, citing a contentious pretrial exchange. Judge Handsel denied the motion but delegated funding decisions to Chief Judge Anthony Rondolino, who granted some requests and denied others, including funding for a PET scan and travel expenses for mitigation specialists. Sexton also waived his right to a jury trial and limited the mitigation evidence presented. The trial court took judicial notice of the original trial transcripts and sentenced Sexton to death, citing three aggravating factors and giving little weight to the mitigating factors.The Supreme Court of Florida reviewed the case and addressed eight issues raised by Sexton. The court found no abuse of discretion in denying funding for a PET scan and travel expenses, noting that Sexton failed to show a particularized need or prejudice. The court also held that the trial court erred in calling Sexton's mitigation specialist as a witness but deemed the error harmless. The court found no violation of Sexton's rights in the trial court's judicial notice of prior proceedings, denial of the motion to disqualify, or comments on Sexton's silence. The court concluded that the trial court properly considered mitigating evidence and understood its discretion in sentencing. Finally, the court rejected Sexton's constitutional challenge to Florida's capital sentencing scheme. The Supreme Court of Florida affirmed Sexton's death sentence. View "Sexton v. State of Florida" on Justia Law

In 1994, Jermaine Foster was convicted of two counts of first-degree murder, one count of attempted first-degree murder, and four counts of kidnapping. The jury recommended two death sentences, which the trial court imposed. The Florida Supreme Court affirmed his convictions and sentences, and the U.S. Supreme Court denied certiorari. Foster later sought postconviction relief based on intellectual disability claims, but the postconviction court denied his motion. The Florida Supreme Court affirmed this denial.Foster filed a successive motion for postconviction relief after the U.S. Supreme Court's decision in Hall v. Florida, which was applied retroactively in Walls v. State. The postconviction court denied his motion without an evidentiary hearing, but the Florida Supreme Court remanded for a Hall-compliant hearing. Before this hearing occurred, the Florida Supreme Court decided Phillips v. State, which held that Hall should not be applied retroactively. The State moved to cancel Foster's hearing, but the postconviction court denied the motion based on the State's concession that it could not deviate from the mandate requiring a hearing.After the Florida Supreme Court's decision in Thompson v. State, which clarified that Phillips represented a change in controlling legal principles, the State renewed its motion for summary denial of Foster's intellectual disability claim. The postconviction court granted this motion, concluding that Phillips constituted an intervening change in law and that Hall did not apply retroactively.The Florida Supreme Court affirmed the postconviction court's denial of Foster's successive motion for postconviction relief. The court held that Foster's intellectual disability claim failed because Hall did not apply retroactively, and the State's initial concession did not preclude it from challenging the retroactive application of Hall. Consequently, Foster's request for an evidentiary hearing was denied. View "Foster v. State" on Justia Law

In 1994, Loran Cole and his companion encountered John Edwards and his sister while they were camping. Cole murdered John and raped his sister. Cole was indicted and found guilty of first-degree murder, kidnapping, robbery, and sexual battery. The jury recommended the death penalty, which the trial court imposed. Cole's convictions and death sentence were affirmed on direct appeal, and his certiorari petition was denied by the U.S. Supreme Court in 1998.Cole filed multiple postconviction relief motions, all of which were denied by the circuit court and affirmed by the Florida Supreme Court. His claims included ineffective assistance of counsel, newly discovered evidence, and constitutional challenges. Cole also sought federal habeas relief, which was denied. His subsequent motions for postconviction relief, including claims based on newly discovered evidence and Hurst v. Florida, were also denied.The Florida Supreme Court reviewed Cole's fourth successive motion for postconviction relief and his public records requests. Cole argued newly discovered evidence regarding his treatment at the Dozier School for Boys, Eighth Amendment violations due to his prison conditions, and the unconstitutionality of Florida's lethal injection procedures. The postconviction court denied these claims as untimely, procedurally barred, or without merit. The Florida Supreme Court affirmed the postconviction court's decision, finding no error in the summary denial of Cole's claims and public records requests. The court also denied Cole's motion to stay his execution and his request for oral argument. View "Cole v. State of Florida" on Justia Law