Justia Florida Supreme Court Opinion Summaries
Bojorquez v. State
The case involves several taxicab companies in Hillsborough County, Florida, which held certificates and permits issued by the Hillsborough County Public Transportation Commission (PTC). The PTC was a special district created by the Legislature to regulate taxicabs. In 2012, a law declared these certificates and permits to be the private property of their holders, allowing them to be transferred or devised. However, in 2017, the Legislature repealed the 2012 law, dissolved the PTC, and returned regulatory authority to Hillsborough County, which chose not to recognize the PTC-issued certificates and permits.The taxicab companies filed a lawsuit claiming that the repeal of the 2012 law and the dissolution of the PTC constituted a taking of their property without compensation, violating the Florida Constitution’s Takings Clause. The trial court granted summary judgment in favor of Hillsborough County, concluding that the certificates and permits had effectively vanished when the PTC was dissolved. However, the court denied the State's motion to dismiss, allowing the possibility of claims for damages against the State.The Second District Court of Appeal affirmed the trial court's judgment in favor of Hillsborough County and reversed the denial of the State's motion to dismiss, holding that the taxicab companies did not have a property interest in the PTC-issued certificates and permits for purposes of the Takings Clause. The taxicab companies then sought review by the Supreme Court of Florida.The Supreme Court of Florida held that the 2017 repeal did not implicate the Florida Constitution’s Takings Clause. The Court concluded that the Legislature retained the discretion to revoke any property rights conveyed in the 2012 law, as the certificates and permits were revocable privileges rather than irrevocable property rights. Consequently, the repeal of the 2012 law did not constitute a taking requiring compensation. The Court approved the decision of the Second District Court of Appeal. View "Bojorquez v. State" on Justia Law
Wilson v. State
In August 2020, Sarah Baker discovered her two sons, Robert and Tayten, brutally murdered in their home. Mark Wilson, the boyfriend of Sarah’s sister, had recently moved into a shed on the Bakers’ property. Evidence, including a hammer and fillet knife with blood, and a note from Wilson, linked him to the crime. Wilson confessed to his mother and law enforcement, detailing the murders and claiming he believed the boys were abusing his daughter. He was charged with first-degree murder, burglary with assault or battery, and burglary of a dwelling while armed.The trial court found Wilson guilty on all counts. During the penalty phase, the jury unanimously found several aggravating factors, including that the murders were committed in a cold, calculated, and premeditated manner (CCP). The trial court agreed with the jury’s findings and sentenced Wilson to death for each murder and a consecutive life sentence for burglary while armed.The Supreme Court of Florida reviewed the case and affirmed the convictions and sentences. The court held that there was credible and competent evidence to support the CCP aggravator, including Wilson’s premeditation and lack of provocation from the victims. The court also found no error in the trial court’s rejection of Wilson’s claim of methamphetamine intoxication at the time of the murders, since there was insufficient evidence to support it. Additionally, the court upheld the admission of victim impact evidence, the denial of a special jury instruction regarding a life sentence, and the use of the word “reasonably” in the jury instructions. The court also rejected Wilson’s arguments against the death penalty and found the evidence sufficient to support the convictions. View "Wilson v. State" on Justia Law
Posted in:
Criminal Law
Rogers v. State
In 1995, Glen Edward Rogers murdered Tina Marie Cribbs in Hillsborough County, Florida. Rogers was convicted of first-degree murder, armed robbery, and grand theft of a motor vehicle. He was sentenced to death, and his conviction and sentence were affirmed on direct appeal. Rogers has since filed multiple postconviction motions, all of which have been denied.Rogers' fourth successive postconviction motion raised three claims: (1) he was unconstitutionally deprived of the right to challenge his conviction and sentence due to a conflict of interest with his counsel, (2) newly discovered evidence of his childhood sexual abuse and trafficking would result in a life sentence on remand, and (3) Florida’s lethal injection procedures are cruel and unusual due to his porphyria diagnosis. The postconviction court summarily denied these claims as untimely, procedurally barred, and/or meritless.The Supreme Court of Florida reviewed the case and affirmed the postconviction court's denial. The court found that Rogers' conflict-of-counsel claim was procedurally barred and without merit, as there was no actual conflict of interest. The newly discovered evidence claim was also found to be procedurally barred and meritless, as the evidence could have been discovered with due diligence. Lastly, the court held that Rogers' method-of-execution claim was untimely and meritless, as he failed to demonstrate that Florida’s lethal injection protocol would cause him substantial and imminent risk of serious illness and needless suffering, and he did not identify a viable alternative method of execution.The Supreme Court of Florida denied Rogers' motion for a stay of execution and his request for oral argument, affirming the summary denial of his fourth successive postconviction motion. View "Rogers v. State" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Hutchinson v. State
Jeffrey G. Hutchinson was convicted of murdering his girlfriend Renee Flaherty and her three children in 1998. After an argument with Renee, Hutchinson drank heavily, returned to her home with a shotgun, and killed Renee and two of her children with single shots to the head. He then shot the third child, Geoffrey, twice, killing him. Hutchinson called 911, admitting to the shootings, and was found by police with gunshot residue on his hands and body tissue from Geoffrey on his leg. He was charged with four counts of first-degree murder and sentenced to death for the murders of the three children.Hutchinson's convictions and death sentences were affirmed on direct appeal by the Florida Supreme Court. He filed multiple postconviction motions, all of which were denied. His initial state postconviction motion and successive motions were also denied, as were his federal habeas petitions. His fourth successive postconviction motion, filed after the Governor signed a death warrant, was denied by the circuit court without an evidentiary hearing.The Supreme Court of Florida reviewed Hutchinson's appeal of the denial of his fourth successive postconviction motion and his habeas corpus petition. The court affirmed the circuit court's denial, rejecting Hutchinson's claims that the warrant period violated his constitutional rights, that the warrant selection process was arbitrary, and that his execution would be cruel and unusual punishment. The court also denied his habeas claims, including his argument that Atkins v. Virginia should extend to individuals with neurocognitive disorders and his challenge to the heinous, atrocious, or cruel (HAC) aggravator. The court denied Hutchinson's requests for a stay and oral argument, and ordered the mandate to issue immediately. View "Hutchinson v. State" on Justia Law
Tanzi v. State
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
Posted in:
Constitutional Law, Criminal Law
Vericker v. Powell
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
Mayfield v. Secretary, Florida Department of State
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
Ford v. State
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
Posted in:
Constitutional Law, Criminal Law
Caylor v. State
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
Posted in:
Criminal Law
Craft v. State of Florida
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
Posted in:
Criminal Law