Justia Florida Supreme Court Opinion Summaries

Law enforcement officers, investigating a suspected drug trafficking operation, obtained a valid search warrant for a residence in Leon County, Florida. When executing the warrant, officers knocked and announced their presence but only stated they had a search warrant seconds before forcibly entering the home. Several individuals, including the respondent, were inside, and officers found drugs, cash, and firearms. The respondent was charged with multiple offenses, including drug trafficking and possession of a firearm by a convicted felon.The respondent filed a motion to suppress the evidence, claiming a violation of section 933.09, Florida Statutes, which requires officers to knock and announce their authority and purpose before forcibly entering a home. The Circuit Court for Leon County granted the motion, relying on Florida Supreme Court precedent from State v. Cable, which required exclusion of evidence for such statutory violations. The State appealed, but the First District Court of Appeal affirmed, emphasizing it was bound by Cable. The First District, however, certified a question to the Florida Supreme Court, highlighting conflicting approaches in other jurisdictions after the United States Supreme Court decision in Hudson v. Michigan, which held that the federal exclusionary rule does not apply to knock-and-announce violations under the Fourth Amendment.The Supreme Court of Florida reviewed the certified question and determined that the exclusionary rule is not required or authorized as a remedy for violations of section 933.09, Florida Statutes. The court receded from its prior decision in Cable, holding that because the statute does not provide an exclusionary remedy and instead prescribes criminal penalties for violations, courts should not impose suppression of evidence. The Florida Supreme Court quashed the First District’s decision and remanded for further proceedings consistent with its ruling. View "State of Florida v. Times" on Justia Law

In December 2017, William Roberts had an argument with his girlfriend, Elizabeth Hellstrom, after which she became unresponsive but was later revived. The next day, Roberts informed a friend that Elizabeth was dead and placed in the trunk of her car, also expressing an intent to commit suicide using a propane tank. Law enforcement was alerted and found Elizabeth’s body in her vehicle and evidence of violence in the camper she shared with Roberts. Roberts was indicted for first-degree murder, and the State sought the death penalty based on his prior violent felony conviction and the especially heinous nature of the crime.Following indictment, Roberts was represented by court-appointed counsel but expressed dissatisfaction and chose to waive his right to a jury trial and his presence at trial, both of which the trial court found to be knowing and voluntary. The case proceeded as a bench trial in the Circuit Court in and for Lake County, which found Roberts guilty of first-degree premeditated murder. During the penalty phase, Roberts waived the presentation of mitigating evidence, and the court eventually sentenced him to death, giving great weight to the statutory aggravators and only slight weight to limited mitigating factors.Roberts appealed to the Supreme Court of Florida, raising multiple claims including the admission of collateral crime evidence, the trial court’s rejection of a statutory mitigator, the use of certain penalty phase evidence, constitutional challenges to the death penalty and Florida’s sentencing scheme, and the lack of a contemporaneous competency hearing. The Supreme Court of Florida held that the trial court did not abuse its discretion in admitting evidence or in its mitigator findings, found no constitutional violation, and affirmed the sufficiency of the nunc pro tunc competency determination. The conviction and death sentence were affirmed. View "Roberts v. State of Florida" on Justia Law

Dusty Ray Spencer was convicted of murdering his wife, Karen Spencer, in 1992. The incident involved a series of violent altercations in the weeks preceding the murder, culminating in Spencer attacking Karen in their backyard, inflicting fatal stab wounds and blunt force trauma. Karen’s teenage son, Timothy Johnson, witnessed and attempted to intervene during both the January 4 and January 18 attacks. Spencer was apprehended and tried, with the jury recommending the death penalty by a seven-to-five vote.Following conviction, the trial court sentenced Spencer to death. On direct appeal, the Supreme Court of Florida affirmed the conviction but vacated the death sentence due to improper consideration of aggravating and mitigating factors, remanding for reconsideration. After further proceedings, the trial court again imposed the death penalty, which the Supreme Court of Florida affirmed. Spencer’s subsequent collateral attacks on his conviction and sentence in both state and federal courts were unsuccessful. In May 2026, nearly three decades after his sentence became final, Governor DeSantis signed Spencer’s death warrant, prompting Spencer to file a third successive motion for post-conviction relief and a request for a stay of execution.The Supreme Court of Florida reviewed the trial court’s summary denial of Spencer’s latest motion. The Court held that Spencer’s claims—challenging the lethal injection protocol based on alleged deviations and his cirrhosis, and asserting a categorical exemption from execution due to his advanced age—were untimely and without legal merit. The Court found that Spencer failed to demonstrate any exception to the one-year filing requirement, did not meet the legal standard for a method-of-execution claim, and was foreclosed from relief based on age. The Supreme Court of Florida affirmed the trial court’s denial of post-conviction relief and declined to stay the execution. View "Spencer v. State" on Justia Law

Gary Richard Whitton was convicted in 1992 of the robbery and first-degree murder of James S. Mauldin. At trial, the State presented evidence that Whitton confessed to a cellmate, Kenneth McCullough, and that a third cellmate, Jake Ozio, overheard the confession. The jury unanimously recommended a death sentence, which the trial court imposed. Whitton’s conviction and sentence were affirmed on direct appeal, and the United States Supreme Court denied certiorari in 1995.Over the ensuing decades, Whitton filed multiple unsuccessful motions for postconviction relief in Florida courts, including claims that Ozio’s testimony was false and that the State knowingly presented it in violation of Giglio v. United States and Brady v. Maryland. These claims were denied, with the Florida Supreme Court finding that Whitton failed to establish that Ozio’s testimony was false or that the State knew of any falsity. Whitton pursued similar claims in federal habeas proceedings, and during those proceedings, Ozio recanted his trial testimony, but acknowledged he had no evidence the State knew it was false.Whitton then filed a second successive motion for postconviction relief in the Circuit Court for Walton County, arguing that Ozio’s recantation and related evidence constituted newly discovered evidence supporting Giglio and Brady claims. The circuit court summarily denied the motion as untimely and procedurally barred. On appeal, the Supreme Court of Florida reviewed the summary denial de novo and affirmed, holding that Whitton’s claims were untimely because he was aware of the relevant facts years earlier, and procedurally barred because similar claims had been previously raised and rejected. The court concluded that the circuit court did not err in summarily denying relief on these grounds and affirmed the denial of Whitton’s second successive motion. View "Whitton v. State of Florida" on Justia Law

The appellant was convicted by a jury in 1986 of two counts of first-degree murder and sentenced to death on both counts after the trial court found four aggravating factors and concluded that mitigating circumstances did not outweigh them. The appellant was twenty-two years old at the time of the offenses. Over the years, he has unsuccessfully challenged his convictions and sentences in both state and federal courts, raising various claims, including intellectual disability and ineffective assistance of counsel.Most recently, the appellant filed his third successive motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, asserting entitlement to a new trial or penalty phase based on newly discovered evidence. He argued that recent scientific consensus and expert reports demonstrate that the human brain is not fully developed until the mid-twenties, and therefore, despite his chronological age, he possessed the maturity of someone under nineteen, rendering him ineligible for the death penalty. He also raised a claim of cumulative error. The Circuit Court for Okeechobee County denied his motion without an evidentiary hearing, adopting the State’s reasoning and finding his claims either procedurally barred or without merit. The court concluded that resolutions or reports concerning brain development did not constitute newly discovered evidence and that his other claims were either previously raised or should have been raised earlier.On appeal, the Supreme Court of Florida reviewed the denial de novo. The Court held that the postconviction court did not err by adopting the State’s reasoning or by denying an evidentiary hearing, as the appellant’s claims were untimely, procedurally barred, or failed to present newly discovered evidence as required by established precedent. The Court further held that the claim of cumulative error also failed because the underlying claims lacked merit or were procedurally barred. The Supreme Court of Florida affirmed the summary denial of relief. View "Harvey v. State of Florida" on Justia Law

A defendant was convicted by a jury of sexual battery with force, battery, and false imprisonment for offenses committed when he was a juvenile. At sentencing, he requested a downward departure from the lowest permissible sentence under Florida’s Criminal Punishment Code, arguing that his status as a youthful offender and his need for specialized mental health treatment justified such a departure. The prosecution opposed, citing his criminal history and the risk of reoffending. The trial court declined to make a finding as to whether there was a valid legal ground for a downward departure and instead ruled that no downward departure was appropriate, ultimately sentencing the defendant to thirty years in prison for sexual battery, five years for false imprisonment (to run concurrently), and time served for battery.On appeal, the defendant argued that the trial court erred in refusing to impose a downward departure sentence. The First District Court of Appeal dismissed this claim, holding that it lacked jurisdiction to review a trial court’s denial of a downward departure sentence. This decision conflicted with the approaches taken by other District Courts of Appeal. While this case was pending, the First District later decided in a different case that it did have jurisdiction to review such decisions for abuse of discretion but emphasized that the appropriate remedy for a meritless claim was affirmance, not dismissal.The Supreme Court of Florida reviewed the case to resolve the jurisdictional question. It held that district courts of appeal have jurisdiction under the Florida Constitution and relevant statutes to review a trial court’s final order denying a downward departure sentence. The court approved prior decisions from other districts that recognized such jurisdiction, quashed the First District’s contrary reasoning in this case, and remanded for further proceedings consistent with its opinion. View "Parrish v. State of Florida" on Justia Law

A dispute arose among residents of a Palm Beach community after Harold Peerenboom sued Isaac and Laura Perlmutter for defamation, alleging they orchestrated a hate mail campaign. The Perlmutters counterclaimed for various torts, including defamation and invasion of privacy, and later sought to amend their counterclaims to add punitive damages against Peerenboom, his attorney William Douberley, and Douberley’s employer, Federal Insurance Company. The Perlmutters alleged that Peerenboom and Douberley improperly collected their DNA and manipulated evidence to falsely implicate them, while Federal Insurance was accused of inadequate oversight.After reviewing the Perlmutters’ evidentiary submission and hearing arguments, the Circuit Court granted their motion to amend and add punitive damages claims. Peerenboom, Douberley, and Federal Insurance appealed. The Fourth District Court of Appeal, sitting en banc, reversed the trial court, holding that the trial court should have denied the motion because the evidence could not support a finding of intentional misconduct or gross negligence by clear and convincing evidence. The Fourth District required that, at the pleading stage, the court must determine whether a reasonable jury could find punitive damages warranted by clear and convincing evidence, considering all evidence from both sides.On review, the Supreme Court of Florida held that, under section 768.72(1), Florida Statutes, the trial court at the pleading stage should only consider the evidence proffered by the claimant and not opposing evidence. The Court further held that the clear and convincing evidence standard does not apply at this stage; instead, the trial court must determine only whether a reasonable person could conclude, based on the claimant’s evidence, that the defendant’s conduct could meet the statutory standard for punitive damages. The court quashed the Fourth District’s decision and remanded for further proceedings consistent with this holding. View "Perlmutter v. Federal Insurance Company" on Justia Law

A utility company serving multiple Florida counties sought approval from the Florida Public Service Commission for a four-year rate plan. As part of its petition, the company requested approval for two accounting measures: the Reserve Surplus Amortization Mechanism-Adjusted Depreciation Parameters (RSAM-ADP) and the Reserve Surplus Amortization Mechanism (RSAM). The RSAM-ADP would result in a reserve surplus, which the RSAM aimed to address. Additionally, the continued use of an acquisition adjustment related to a prior corporate purchase became an issue during the proceedings.The Public Service Commission received and considered various depreciation proposals from both the utility and the Office of Public Counsel (OPC), as well as testimony regarding the appropriateness and impact of the RSAM-ADP and RSAM. The Commission approved the RSAM-ADP, recognizing it would result in a reserve surplus, and then approved the RSAM as a corrective measure. The Commission also allowed the continued amortization of the acquisition adjustment until the utility’s next rate case. OPC filed a motion for reconsideration, which was denied, and then appealed the Commission’s decisions to the Supreme Court of Florida.The Supreme Court of Florida reviewed whether the Commission’s actions were consistent with its rules, policy, and prior practice, and whether its decisions were supported by competent, substantial evidence. The Court held that the Commission’s approval of the RSAM-ADP and RSAM was not inconsistent with the applicable depreciation rule, did not violate official policy or prior practice, and was supported by substantial evidence. The Court also found that the continuation of the acquisition adjustment was neither contrary to official policy nor lacking evidentiary support. The Supreme Court of Florida affirmed the Commission’s final and clarifying orders. View "Citizens of the State of Florida v. Florida Public Service Commission" on Justia Law

An employee in Florida was terminated by his employer after raising several workplace safety concerns. The employer stated that the termination was due to the employee's use of racially disparaging language, following a series of disciplinary actions. The employee subsequently filed suit, alleging that his dismissal was in retaliation for objecting to what he believed were illegal safety practices, in violation of Florida’s private sector Whistle-Blower’s Act.After discovery, the employer moved for summary judgment in the Circuit Court, arguing that the employee failed to show he had objected to actual violations of law, rule, or regulation. The employee countered that it was sufficient to show he had a good faith, objectively reasonable belief that the practices he objected to were illegal. The trial court sided with the employer, holding that the statute required objection to an actual, not suspected, violation. The First District Court of Appeal affirmed, aligning with decisions from the Second and Fifth Districts and certifying conflict with the Fourth District, which had adopted a “good faith, objectively reasonable belief” standard.The Supreme Court of Florida reviewed the case to resolve this conflict among the district courts of appeal. The Court held that, under section 448.103 and section 448.102(3), Florida Statutes, an employee must prove by a preponderance of the evidence that the employer’s activity, policy, or practice to which the employee objected is, by definition, in violation of law. It is not enough for the employee simply to have a subjective, good faith, or objectively reasonable belief that the employer’s conduct was illegal. The Court approved the result reached by the First District but clarified the applicable legal standard. View "Gessner v. Southern Company" on Justia Law

In this case, the appellant was convicted and sentenced to death for the 1996 murder of a five-month-old child in Jacksonville, Florida. The appellant, who was living with the victim’s mother at the time, initially claimed the child had been abducted, prompting an extensive police search. He later confessed to killing the child and disposing of her body in a pond. At trial, the appellant’s explanations about the cause of death were inconsistent with the medical evidence, which showed multiple fatal head injuries. The jury convicted him of first-degree murder and aggravated child abuse, and he was sentenced to death based partly on aggravating factors including a prior conviction for child abuse.After his conviction and sentence were affirmed by the Supreme Court of Florida on direct appeal, the appellant pursued multiple rounds of postconviction relief in both state and federal courts, all of which were unsuccessful. Most recently, following the signing of a death warrant, the appellant filed a third successive postconviction motion in the Circuit Court for the Fourth Judicial Circuit. He argued that Florida’s lethal injection protocol was unconstitutional as applied to him and on its face, that the short period between the warrant and execution deprived him of due process, and that he was wrongly denied additional public records. The circuit court summarily denied all claims.The Supreme Court of Florida reviewed the circuit court’s summary denial de novo and affirmed. The court held that the as-applied and facial Eighth Amendment challenges to Florida’s lethal injection protocol were both untimely and meritless. The court also found no due process violation in the expedited warrant litigation schedule and no abuse of discretion in denying the requests for additional public records. The appellant’s motion for a stay of execution was denied, and the summary denials of postconviction relief and records requests were affirmed. View "Lukehart v. State" on Justia Law