Justia Florida Supreme Court Opinion Summaries

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

In December 1990, Victor Tony Jones fatally stabbed his employers, Jacob and Matilda Nestor, during a robbery at their business in Miami-Dade County. Jones was found at the scene with the victims’ belongings and admitted to the killings at the hospital. He was convicted by a jury of two counts of first-degree murder and two counts of armed robbery. The trial court, following the jury’s recommendation, imposed death sentences for both murders, citing three aggravating factors and no mitigation. The Florida Supreme Court affirmed the convictions and sentences, and the United States Supreme Court denied certiorari in 1995.Over the following decades, Jones filed multiple unsuccessful motions for postconviction relief in the Circuit Court for Miami-Dade County and petitions for habeas corpus in state and federal courts. After Governor Ron DeSantis signed Jones’s death warrant in August 2025, Jones filed a sixth successive motion for postconviction relief, arguing newly discovered evidence of abuse at the Okeechobee School for Boys, racial disparities in Miami-Dade capital prosecutions, and due process violations in the warrant process. He also made post-warrant demands for public records related to the Okeechobee School. The circuit court summarily denied all claims and records requests.The Supreme Court of Florida reviewed the appeal and petition. It held that Jones’s claim of newly discovered evidence regarding abuse at the Okeechobee School was procedurally barred and meritless, as the alleged abuse was known to Jones long before trial and did not constitute evidence likely to yield a life sentence on retrial. The court also found no due process violation in the warrant process and no abuse of discretion in denying Jones’s public records requests. The habeas petition was denied as an improper attempt to relitigate previously decided issues. The court affirmed the circuit court’s orders, denied all relief, and refused to entertain any rehearing. View "Jones v. State" on Justia Law

In this case, the defendant was found guilty by a jury of being a violent career criminal (VCC) in possession of a firearm, following an incident in which he brandished and fired a gun during an argument. To establish his VCC status, the State relied on three prior convictions: aggravated battery, burglary, and escape. While the defendant did not contest the first two convictions as qualifying offenses, he argued that his 1995 escape conviction, which arose from an escape from a juvenile detention facility, should not count as a predicate offense under the VCC statute.On direct appeal, the Florida Second District Court of Appeal agreed with the defendant that the juvenile escape conviction was not a qualifying offense under the VCC statute. However, the court affirmed the conviction because the defendant had not preserved this argument at trial, and the error was not considered “fundamental” under the standard set by the Supreme Court of Florida in F.B. v. State. The Second District found that, since the evidence at trial established at least the lesser included offense of felon in possession of a firearm, the error did not reach the level of fundamental error requiring reversal.The Supreme Court of Florida reviewed the case due to a conflict with other district courts on the issue of fundamental error in evidence insufficiency cases. The Court ultimately held that the defendant’s 1995 juvenile escape conviction does qualify as a predicate offense for VCC status. The Court reasoned that the relevant statutes expressly state that escape from a juvenile facility constitutes escape within the meaning of the adult escape statute, and the legislative scheme supports treating such convictions as qualifying offenses. Accordingly, the Supreme Court of Florida approved the judgment affirming the defendant’s conviction. View "Pryor v. State of Florida" on Justia Law

In 1990, the defendant was convicted of first-degree murder, kidnapping, and robbery after abducting a woman from a bar, fatally stabbing her, and leaving her body by a dirt road. Physical evidence, including fingerprints, blood, and items from the bar found near his home, linked him to the crime. The jury recommended a death sentence, which the trial court imposed, finding multiple aggravating factors. The Florida Supreme Court affirmed his convictions and sentence on direct appeal.Over the following decades, the defendant filed numerous postconviction motions and habeas petitions, all of which were denied by various courts, including the Florida Supreme Court. In his third and fourth successive postconviction motions, he raised claims based on alleged newly discovered evidence, including declarations that a serial killer confessed to the murder, a witness’s willingness to recant, and purported evidence of prosecutorial misconduct. He also asserted claims under Jones v. State, Brady v. Maryland, Giglio v. United States, and Massiah v. United States, as well as a due process claim regarding a prior appellate decision. The Circuit Court for Walton County summarily denied all claims, finding most to be untimely or procedurally barred under Florida Rule of Criminal Procedure 3.851, and rejecting others on the merits.The Supreme Court of Florida reviewed the summary denial de novo and affirmed. The court held that the defendant’s claims were untimely and procedurally barred because he failed to demonstrate due diligence in discovering the alleged new evidence or to show that the claims could not have been raised earlier. The court also found that the purported new evidence was inadmissible or would not probably produce an acquittal at retrial. Additionally, the court concluded that the due process claim was meritless and that the circuit court correctly denied relief. The summary denials of the third and fourth successive postconviction motions were affirmed. View "Suggs v. State of Florida" on Justia Law

While serving a forty-year sentence at Mayo Correctional Institution, Jesse Bell and his cellmate planned and executed the murder of another inmate as a rehearsal for a subsequent planned attack on a correctional officer. On June 26, 2019, they killed the inmate and later that day attempted to kill the officer, who survived. Bell confessed to the crimes and was indicted for first-degree murder, attempted murder, conspiracy, and possession of contraband. Shortly after counsel was appointed, Bell waived his right to counsel and a penalty-phase jury, entered a no-contest plea, and represented himself during sentencing. The court found multiple aggravating factors and sentenced Bell to death.The Circuit Court for Lafayette County conducted the trial and sentencing. On direct appeal, the Supreme Court of Florida affirmed Bell’s conviction and death sentence, finding his waivers and plea were knowing and voluntary, and that he was not deprived of an individualized sentencing. Bell then filed a motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, arguing his waivers were involuntary due to prison abuse, that counsel was ineffective for not investigating this abuse, and that he was denied individualized sentencing. The circuit court summarily denied the motion, finding the claims procedurally barred or refuted by the record.The Supreme Court of Florida reviewed the summary denial and Bell’s habeas petition. The court held that Bell’s postconviction claims were procedurally barred because they could have been raised on direct appeal, and that the record showed his waivers were voluntary. The court also found no ineffective assistance of counsel or appellate counsel, as there was no evidence of prejudice or deficient performance. The order denying postconviction relief was affirmed, and habeas relief was denied. View "Bell v. State of Florida" on Justia Law

In 1982, Kayle Barrington Bates committed a series of violent crimes, including robbery, attempted sexual battery, and the murder of Janet Renee White. Bates was apprehended near the scene shortly after the attack, and physical evidence, as well as his own admissions, linked him to the crimes. He was charged with first-degree murder, kidnapping, attempted sexual battery, and armed robbery. A jury found him guilty on all counts and recommended a death sentence.After his initial conviction and sentencing, the Supreme Court of Florida affirmed the convictions but vacated the death sentence due to insufficient evidence supporting two aggravating factors, remanding for resentencing. On remand, the trial court again imposed the death penalty, which the Supreme Court of Florida affirmed. Bates pursued multiple rounds of postconviction relief in both state and federal courts, raising various constitutional and evidentiary claims, all of which were denied. His most recent efforts included a fourth successive postconviction motion and a petition for a writ of habeas corpus, following the signing of a new death warrant.The Supreme Court of Florida, exercising its mandatory review jurisdiction, affirmed the circuit court’s summary denial of Bates’ fourth successive postconviction motion and the denial of his public records requests. The court found Bates’ claims to be untimely, procedurally barred, or previously litigated and rejected. The court also denied his habeas petition, finding all claims either procedurally barred or without merit. The court denied Bates’ requests for a stay of execution and oral argument, and ordered that no motion for rehearing would be considered, with the mandate to issue immediately. The main holding is that Bates is not entitled to postconviction or habeas relief, and his execution may proceed. View "Bates v. State" on Justia Law

Edward J. Zakrzewski, II, was sentenced to death for the murders of his wife, Sylvia, and two minor children, Edward and Anna, which he committed on June 9, 1994. Zakrzewski pled guilty to all three murders and was sentenced to death for each, with the trial court overriding the jury's recommendation of life imprisonment for Anna's murder. The trial court found three aggravating factors for each murder and gave significant weight to both statutory and nonstatutory mitigators.On direct appeal, the Florida Supreme Court affirmed Zakrzewski’s convictions and sentences. The United States Supreme Court denied certiorari review, making the sentences final. Over the next three decades, Zakrzewski sought postconviction relief multiple times in both state and federal courts, all of which were denied. His federal habeas petition was denied by the Northern District of Florida, and the Eleventh Circuit Court of Appeals affirmed the denial. Zakrzewski also filed several motions for postconviction relief under Florida Rule of Criminal Procedure 3.851, all of which were denied by the Florida Supreme Court.Governor Ron DeSantis signed Zakrzewski’s death warrant on July 1, 2025, setting an execution date of July 31, 2025. Zakrzewski filed his fifth successive motion for postconviction relief, raising three claims, which the Circuit Court of the First Judicial Circuit summarily denied. Zakrzewski appealed the denial, raising four arguments.The Supreme Court of Florida affirmed the circuit court’s summary denial of Zakrzewski’s fifth successive postconviction motion. The court found Zakrzewski’s claims untimely, procedurally barred, and meritless. The court also rejected Zakrzewski’s claims regarding the Governor’s discretion in signing death warrants and the lack of a recent clemency review. Additionally, the court upheld the circuit court’s denial of Zakrzewski’s requests for public records, finding no abuse of discretion. The court denied Zakrzewski’s motion for a stay of execution and request for oral argument. View "Zakrzewski v. State" on Justia Law