Justia Florida Supreme Court Opinion Summaries

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The Supreme Court affirmed the order of the circuit court summarily denying Appellant's successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief.Appellant was convicted of first-degree murder. In a seven-to-five vote recommendation the jury sentenced Appellant to death, and the death sentence became final in 1989. In his postconviction motion, Appellant argued that he was entitled to retroactive application of the Supreme Court's decision in State v. Poole, 297 So. 3d 487 (Fla. 2020), which receded from Hurst v. State, 202 So. 3d 40 (Fla. 2016) except as to the requirement that a jury must unanimously find the existence of a statutory aggravating circumstance beyond a reasonable doubt. The Supreme Court denied relief, holding that Poole did not retroactively apply to Appellant. View "Jackson v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed Defendant's convictions for first-degree murder and sentences of death, holding that the introduction of the testimony of Defendant's mother constituted harmful error.During Defendant's trial, Defendant's mother, Jeanne Avsenew, testified regarding multiple incriminating statements made and actions taken by Defendant shortly after the murders. At issue was whether the perpetuated testimony testimony of Jeanne, which was given despite her inability to see Defendant during her testimony, violated Fla. R. Crim. P. 3.190(i)(3), which requires that the defendant be in the witness's presence during testimony. The Supreme Court reversed, holding (1) the failure to ensure that Defendant was kept in the presence of his mother during her testimony constituted a clear violation of Rule 3.190(i)(3); and (2) the error was not harmless. View "Avsenew v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated Defendant's convictions for first-degree murder and remanded this case to the trial court for a new trial, holding that Defendant was entitled to postconviction relief as to the guilt phase of his trial.A jury found Defendant guilty of two murders, and the trial court ultimately imposed a sentence of death for each murder. The Supreme Court affirmed on direct appeal. Defendant subsequently filed a motion for postconviction relief, raising several Brady claims as to the guilt phase of his trial. The postconviction court denied relief. The Supreme Court reversed the denial of postconviction relief as to the guilt phase and vacated Defendant's murder convictions, holding (1) the State committed a Brady violation by failing to disclose that one of the witnesses was a confidential informant for the State; and (2) the Brady violation undermined confidence in the outcome of the trial. View "Simpson v. State" on Justia Law

Posted in: Criminal Law
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In this considering the provisions of a personal injury protection (PIP) insurance policy permit permitting the insurer to limit reimbursement payments in accordance with a statutory schedule of maximum charges the Supreme Court held that the PIP policy in this case was effective to authorize the use of the schedule of maximum charges under the pertinent provisions of Fla. Stat. 627.736(5).The certified question in this case related to the Second District Court of Appeal's holding that State Farm's policy provisions permitted State Farm to use the schedule of maximum charges even though the policy also referred to the use of other statutory factors for determining reasonable charges. The Supreme Court affirmed, holding that the PIP policy issued by State Farm was effective to authorize the use of the schedule of maximum charges under the relevant provisions of Fla. Stat. 627.736(5). View "MRI Associates of Tampa, Inc. v. State Farm Mutual Automobile Insurance Co." on Justia Law

Posted in: Insurance Law
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The Supreme Court held that when a defendant voluntarily chooses to allocate at a sentencing hearing, the sentencing court is permitted to consider the defendant's freely offered statements, including those indicating the defendant's failure to accept responsibility.On appeal from the judgment of the trial court in this case, the First District concluded that "lack of remorse and refusal to accept responsibility can be valid sentencing considerations when sentencing within the statutory range." The Supreme Court approved the result in the decision on review, holding that the sentencing judge in this case was entitled to consider testimony that indicated Defendant's unwillingness to accept the truth and to take responsibility for his conduct. View "Davis v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court sanctioned Petitioner after dismissing his petition for a writ of habeas corpus, holding that Petitioner failed to show cause why he should not be barred from filing any further pro se requests for relief.Since 2018, Petitioner, who was convicted of false imprisonment and aggravated battery, had filed sixteen petitions with the Supreme Court, including the petition at issue in this case, all without success. The Supreme Court dismissed the instant petition as a repetitive claim and held that, based on Petitioner's history of filing pro se petitions and requests for relief that were meritless or otherwise inappropriate for review, the clerk of court should reject any future pleadings or requests for relief submitted by Petitioner pertaining to his criminal case. View "Martin v. Dixon" on Justia Law

Posted in: Criminal Law
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The Supreme Court approved the stipulation entered into by Palm Beach County Judge Marni Bryson and the Florida Judicial Qualifications Commission (JQC) that Judge Bryson be publicly reprimanded, suspended without pay for ten days, and pay a $37,500 fine, concluding that Judge Bryson acted inappropriately by failing to devote full time to her judicial duties.The JQC found that Judge Bryson was absent from the courthouse beyond the permitted number of days for judicial leave, failed to make appropriate notifications of some absences to appropriate court management, and was sometimes in the courthouse for less than a full workday. Judge Bryson admitted her conduct in the stipulation, and the JQC found that Judge Bryson's actions violated Canons 3A and 3B(4) for the Florida Code of Judicial Conduct. The Supreme Court approved the stipulation of the parties and ordered that Judge Bryson be publicly reprimanded and pay a $37,500 fine. View "Inquiry Concerning Judge Marni A. Bryson" on Justia Law

Posted in: Legal Ethics
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The Supreme Court approved the holding of the Second District Court of Appeal in this case, which involved an appeal of a conviction for driving as a habitual traffic offender (HTO) while one's driver's license is revoked (DWLR-HTO), holding that the court below reached the correct result.The district court held that, under Fla. Stat. 322.34(5), a conviction for DWLR-HTO does not require the State to prove that the Florida Department of Highway Safety and Motor Vehicles (DHSMV) provided Defendant with notice of the HTO driver license revocation. The Supreme Court approved the district court's ruling, holding that proof that DHSMV provided a defendant with notice of an HTO driver license revocation is not an element of the crime of DWLR-HTO under section 322.34(5). View "Robinson v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court held that the wrongful death action at issue in this case was covered by the Legislature's 1999 amendment of Fla. Stat. 768.73.In 1999, the Legislature amended section 768.73 to presumptively preclude an award of punitive damages against a defendant in a civil action if “punitive damages have previously been awarded against that defendant in any state or federal court in any action alleging harm from the same act or single course of conduct for which the claimant seeks compensatory damages" and made the amendments applicable "to all causes of action arising after" October 1, 1999. The certified conflict at issue in this case was whether the amendments applied to Engle progeny wrongful death actions where the smoking-injured decedent died after October 1, 1999. The Fifth District Court of Appeal held that the 1999 amendments applied to Petitioner's Engle progeny wrongful death action against Respondent, on which "numerous prior punitive damages awards" had been imposed previously. The Supreme Court affirmed, holding that the 1999 amendments apply in Engle progeny wrongful death actions in which the decedent died after the effective date of the amendments. View "Sheffield v. R.J. Reynolds Tobacco Co." on Justia Law

Posted in: Personal Injury
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The Supreme Court approved the decision of the First District Court of Appeal in this case, holding that Fla. Stat. 942.051(3), which prohibits raising an unpreserved claim of error on direct appeal absent a showing of fundamental error, precludes appellate review of unpreserved claims of ineffective assistance of trial counsel on direct appeal.Defendant was found guilty of first-degree murder. On appeal, Defendant argued that he received ineffective assistance of counsel. The First District affirmed Defendant's convictions and sentence and declined to address his claims of ineffective assistance because he did not preserve any of the errors he advanced on appeal and did not make a claim of fundamental error. The Supreme Court approved of the decision below, holding that the plain text of section 924.051 prohibits raising unpreserved error on direct appeal absent a showing of fundamental error. View "Steiger v. State" on Justia Law