Justia Florida Supreme Court Opinion Summaries

The case concerns the termination of S.H.’s parental rights to her daughter, K.W., who is recognized as an Indian child under the Indian Child Welfare Act (ICWA). The Florida Department of Children and Families sought to terminate S.H.’s parental rights, and the circuit court conducted a multi-day adjudicatory hearing. The court found, by clear and convincing evidence, that the statutory grounds required under Florida law for termination were met. Additionally, because K.W. is an Indian child, the court applied the ICWA’s higher “beyond a reasonable doubt” standard to determine that continued custody by S.H. would likely result in serious emotional harm to K.W.S.H. appealed to the Florida Sixth District Court of Appeal, arguing that the ICWA’s “beyond a reasonable doubt” burden should apply not only to the federal finding but also to the separate findings required by Florida law for termination. The Sixth District rejected this argument, holding that the ICWA did not preempt Florida’s clear and convincing evidence standard for its distinct statutory findings. The court thus affirmed the circuit court’s decision. S.H. sought further review, pointing out a conflict with the Florida First District Court of Appeal’s decision in J.P.H. v. Florida Department of Children & Families, which had applied the ICWA’s higher standard more broadly.The Supreme Court of Florida reviewed the case to resolve this conflict. It held that the ICWA does not preempt the clear and convincing evidence standard that Florida law applies to its separate statutory findings required for termination of parental rights. Instead, the ICWA’s “beyond a reasonable doubt” standard applies solely to the specific finding regarding the likelihood of serious harm from continued custody. The Court approved the Sixth District’s decision and disapproved J.P.H. where inconsistent. View "S.H. v. Department of Children and Families" on Justia Law

While serving a life sentence for a prior first-degree murder, the defendant fatally stabbed his cellmate, John Anderson, in a Florida prison. He confessed multiple times to the killing, including in letters and statements to officials, and was charged with first-degree premeditated murder. Evidence at trial established the murder was planned, brutal, and motivated in part by racial animus. The jury heard testimony about the violence, the aftermath, and the defendant’s personal history, including a dysfunctional upbringing and mental health issues.After a trial in the Circuit Court for Indian River County, the jury unanimously found the defendant guilty of first-degree murder and recommended a death sentence. The trial court assigned significant weight to four aggravating factors—prior violent felony, heinous, atrocious or cruel nature of the crime, cold, calculated, and premeditated manner, and being under sentence of imprisonment—while recognizing mitigating evidence related to the defendant’s upbringing and mental health. The death sentence and conviction were affirmed by the Supreme Court of Florida on direct appeal.The defendant subsequently filed initial and successive motions for postconviction relief under Florida Rules of Criminal Procedure, as well as a habeas corpus petition. He raised claims of ineffective assistance of counsel, alleged violations under Giglio and Napue, and sought relief based on newly discovered evidence of seizure disorder and brain damage. He also requested additional public records and medical testing. The Supreme Court of Florida reviewed these claims de novo and found them to be either procedurally barred, insufficiently pleaded, cumulative, or meritless. The Court affirmed all circuit court orders denying relief and denied the petition for habeas corpus. View "Craven v. State of Florida" on Justia Law

A homeowner held an insurance policy with an insurer from April 2019 to April 2020. After experiencing water damage, she filed a claim in May 2019. The insurer paid part of the claim, but the homeowner disputed the amount and requested additional payment based on independent repair bids. On July 1, 2021, a new Florida statute went into effect requiring claimants to provide presuit notice to the state Department of Financial Services before suing an insurer over a property policy. In August 2021, the homeowner filed suit against her insurer over the 2019 claim without providing this notice.The trial court, a Florida circuit court, dismissed her complaint without prejudice, holding that the presuit notice requirement applied retroactively to her claim, even though her policy was issued before the statute’s effective date. On appeal, the Sixth District Court of Appeal reversed, finding no clear legislative intent for retroactive application of the statute. The appellate court concluded that the statute’s language about applying to “all suits” did not provide a clear command for retroactivity and rejected contrary reasoning from the Fourth District Court of Appeal in Cole v. Universal Property & Casualty Insurance Co.The Supreme Court of Florida reviewed the case to resolve a conflict among the district courts of appeal. The Court held that the presuit notice requirement in section 627.70152, Florida Statutes, does not apply retroactively to insurance policies issued before the statute’s effective date. The Court found no clear legislative intent for retroactive application in the statutory text, and it concluded that the statute significantly altered substantive rights and obligations. The Supreme Court affirmed the Sixth District’s decision and disapproved the Fourth District’s contrary holding. View "Universal Property & Casualty Insurance Company v. Hughes" on Justia Law

A Florida Highway Patrol officer stopped Richard Rhodes in March 1984 while he was driving a car registered to Karen Nieradka. Rhodes was arrested for driving without a valid license and held in the Citrus County Jail. Weeks later, Nieradka’s decomposed body was discovered in construction debris in St. Petersburg, with the medical examiner determining manual strangulation as the cause of death. Detectives interviewed Rhodes, who gave inconsistent statements but always denied killing Nieradka. After further investigation, Rhodes was arrested for her murder. At trial, several jailhouse informants testified that Rhodes confessed to the killing; Rhodes was convicted of first-degree murder and sentenced to death.On direct appeal, the Supreme Court of Florida affirmed the conviction but remanded for resentencing, which again resulted in a death sentence and was affirmed. Rhodes later filed multiple postconviction motions. In the most recent proceeding, he filed a successive motion under Florida Rule of Criminal Procedure 3.851, submitting affidavits from jailhouse witnesses who recanted or claimed their trial testimony had been elicited or coached by the State in exchange for leniency or other benefits. At an evidentiary hearing, these witnesses testified, but their accounts were contradicted by State witnesses and records. The postconviction court found Rhodes’s witnesses not credible and denied all relief.The Supreme Court of Florida reviewed the denial of postconviction relief, applying deference to the lower court’s credibility findings and reviewing legal conclusions de novo. The court held that the postconviction court’s findings regarding witness credibility were supported by competent, substantial evidence. Rhodes failed to establish a violation under Brady v. Maryland, Giglio v. United States, or Massiah v. United States, and the affidavits did not constitute newly discovered evidence warranting a new trial. The Supreme Court of Florida affirmed the denial of Rhodes’s successive motion for postconviction relief. View "Rhodes v. State of Florida" on Justia Law

In this case, the defendant was convicted and sentenced to death for a 2003 murder. The victim, a young man, was found strangled and stabbed in a motel room. The defendant had worked with the victim and became a suspect when his vehicle matched that associated with another double homicide. Physical evidence included a hair and shoe impressions linking the defendant to the scene. The prosecution also presented evidence of the defendant’s involvement in other similar murders. At trial, the State argued that the murder involved sadistic sexual assault, relying in part on DNA evidence found on the victim, which was attributed to another individual living at the motel.Following the conviction, the defendant sought postconviction relief in the Circuit Court, arguing, among other things, that the State had withheld evidence in violation of Brady v. Maryland. The evidence in question consisted of Florida Department of Law Enforcement (FDLE) call logs indicating that analysts believed the DNA found was unlikely to be the result of secondary transfer, contrary to the State’s theory at trial. The postconviction court found that this evidence was withheld and was favorable to the defense, but concluded it was not exculpatory and denied relief.The Supreme Court of Florida reviewed the appeal. The Court held that the State violated its obligations under Brady by suppressing material impeachment evidence regarding the likelihood of secondary DNA transfer. The undisclosed evidence could have impeached key State witnesses and undermined the prosecution’s theory. The Court found that the suppressed evidence was material and that its absence prejudiced the defendant, creating a reasonable probability of a different verdict. Accordingly, the Supreme Court of Florida reversed the postconviction court’s denial of relief, set aside the conviction, and remanded for a new trial. View "Jones v. State of Florida" on Justia Law

The appellant was convicted of first-degree murder, robbery, and grand theft after brutally beating and killing a woman with whom he was temporarily staying. Evidence at trial established the appellant stole cash and the victim’s car, fled the state, and used an alias before being apprehended in Alabama and returned to Florida for prosecution. The jury convicted him and recommended the death penalty by a 10-2 vote. The trial court found aggravating factors including murder during a robbery and that the crime was especially heinous, atrocious, or cruel, outweighing mitigating circumstances, and imposed a sentence of death.The Supreme Court of Florida previously affirmed the convictions and sentence on direct appeal. The appellant later filed multiple unsuccessful postconviction motions in state and federal courts, including a motion based on the Florida Supreme Court’s decision in Hurst v. State, which was denied due to lack of retroactivity. After the Governor signed a death warrant, the appellant filed a successive motion for postconviction relief and a stay of execution in the Circuit Court for Polk County, raising claims regarding his age and cognitive decline, warrant timing, the warrant process, and the nonunanimous jury recommendation.The Supreme Court of Florida reviewed the circuit court’s summary denial of postconviction relief de novo. The Court affirmed the summary denial, holding the appellant’s claims were either procedurally barred or meritless. Specifically, it ruled there is no constitutional prohibition against executing elderly prisoners experiencing cognitive decline, the expedited warrant period does not violate due process or equal protection, the Governor’s discretion in signing death warrants is not unconstitutional, and a nonunanimous jury recommendation of death does not violate the Fifth, Sixth, or Eighth Amendments. The Court also denied the appellant’s request for a stay of execution. View "Beasley v. State" on Justia Law

The case centers on a home invasion and murder that occurred in Lakeland, Florida in 2013. Mark Wilkerson, residing with his family, encountered two men outside his home, one of whom, Benjamin Davis Smiley, Jr., pointed a gun at him and demanded information about a safe. After robbing Wilkerson and forcing him into the house, Smiley entered the bedroom of Clifford Drake, Wilkerson’s stepfather, and shot Drake fatally after demanding money. Smiley and his accomplice, Casey Bisbee, fled, leaving behind a backpack. The investigation went cold until DNA evidence from the backpack and a discarded sweatshirt matched Smiley nearly two years later. Wilkerson later identified Smiley in a photographic lineup, and phone records showed Smiley’s involvement. Testimony from associates further implicated Smiley in planning and carrying out the robbery.Following these events, Smiley was charged with first-degree murder and related crimes. The State sought the death penalty. The Circuit Court in Polk County admitted limited evidence connecting the murder weapon to another homicide for which Smiley was also charged. At trial, the jury found Smiley guilty on all counts. During the penalty phase, mitigating evidence about Smiley’s brain injuries was presented, but the jury unanimously recommended death, and the court imposed a death sentence after finding aggravating factors outweighed mitigation.Smiley appealed, raising numerous claims, most alleging ineffective assistance of trial counsel. The Supreme Court of Florida affirmed the circuit court’s denial of his postconviction motion, finding counsel’s performance was not deficient or prejudicial under the standards set by Strickland v. Washington. Additionally, the Court denied Smiley’s habeas petition, concluding that any alleged errors by appellate counsel were harmless and did not undermine confidence in the outcome. The main holding is that neither Smiley’s conviction nor his sentence were affected by ineffective assistance of counsel, and no grounds for postconviction or habeas relief were established. View "Smiley v. Secretary, Department of Corrections" on Justia Law

A man was convicted and sentenced to death for the murder and kidnapping of another individual, whose body was found in a remote wooded area after he went out to earn money by posing for nude photographs. The victim suffered strangulation and other trauma, and investigators found evidence linking the defendant to the scene, including paint chips matching his father’s car and records of purchases made shortly before the murder. Prior to this incident, the defendant had assaulted another victim in a similar manner. The evidence presented at trial included testimony from medical experts, forensic analysis, and corroboration from law enforcement investigations.After his conviction, the defendant pursued multiple collateral challenges in state and federal courts, including motions for post-conviction relief and DNA testing under Florida Rules of Criminal Procedure 3.851 and 3.853. The Circuit Court in and for Charlotte County summarily denied his third and fourth successive motions for post-conviction relief, as well as his motion for DNA testing. The defendant appealed these denials, requested a stay of execution, and filed a petition for a writ of habeas corpus in the Supreme Court of Florida. The appeals and petition were consolidated for review.The Supreme Court of Florida affirmed the trial court’s summary denials, finding that the defendant’s claims of newly discovered evidence were based on information that could have been obtained earlier through due diligence and did not meet procedural requirements. The Court also held that advances in DNA testing did not create a reasonable probability of a different outcome, and that expedited post-warrant proceedings did not violate due process. The habeas petition was found to be procedurally barred and lacking in merit. Accordingly, the Court denied all relief, including the request for a stay of execution. View "Conahan v. State" on Justia Law

Nearly forty years ago, the defendant was convicted of the sexual battery and first-degree murder of an eleven-year-old child. After the Governor signed a warrant for execution in February 2026, the defendant filed several postconviction motions. These included a motion for DNA testing of a sample from the victim's underwear and a fifth successive motion for postconviction relief. The circuit court granted the DNA testing request but denied the postconviction relief motion. DNA testing did not exonerate the defendant, and the stay of execution was lifted.Following those events, the defendant filed a second post-warrant motion for DNA testing, seeking analysis of additional items, as well as a sixth successive motion for postconviction relief. The Circuit Court for Lake County summarily denied both motions, finding the DNA testing request was procedurally barred because the defendant could have sought testing of those items earlier. The court also determined there was no testable genetic material on the items requested for testing. Regarding the postconviction motion, the court rejected the defendant’s claim that the State violated due process by not sending a sample to a Texas laboratory for a different DNA testing method, finding no evidence of bad faith by the State in consuming the sample during testing.On appeal, the Supreme Court of Florida affirmed the circuit court’s summary denial of both motions. The Court held that the DNA testing motion was procedurally barred and meritless, as no DNA existed on the items sought to be tested. The Court also held that the defendant failed to demonstrate bad faith by the State under Arizona v. Youngblood in the destruction of evidence during DNA testing. The Court denied the motion for stay of execution and stated that no motion for rehearing would be considered. View "Duckett v. State" on Justia Law

The case centers on a man convicted and sentenced to death for the 1986 murder of his ex-girlfriend’s mother in Florida. On the night of the crime, he returned to his ex-girlfriend’s home after being refused entry, armed himself, and cut the phone lines before fatally shooting the woman’s father outside and, after breaking in, shooting her mother inside. The jury recommended death for both murders, but the judge imposed a life sentence for the father's death and a death sentence for the mother's, finding several aggravating factors. Since his conviction became final in 1991, he has unsuccessfully challenged his conviction and sentence in multiple state and federal proceedings.After a death warrant was signed in 2026, he filed a second successive motion for postconviction relief in the Circuit Court for Pasco County, arguing: (1) that alleged shortages of the lethal injection drug etomidate and possible deviations from execution protocols violated his constitutional rights; (2) that executing him at his advanced age would constitute cruel and unusual punishment; and (3) that the pace of executions in Florida and the circumstances of his case rendered his execution unconstitutional and a manifest injustice. The circuit court summarily denied these claims, along with his requests for public records and a stay of execution.The Supreme Court of Florida reviewed the appeal and affirmed the circuit court’s summary denial. The court held that the public records request was properly denied because it was not tied to a colorable claim for postconviction relief and found the equal protection and Eighth Amendment challenges speculative, untimely, or lacking merit. The court also rejected arguments based on the pace of executions, alleged psychological effects on prison staff, and the sufficiency of the jury’s death recommendation under current law. The motion for a stay of execution was also denied, and the mandate was ordered to issue immediately. View "Occhicone v. State" on Justia Law