Justia Florida Supreme Court Opinion Summaries

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In this child sexual abuse case concerning the separation of powers and the proper role of courts in applying statutes of limitations the Supreme Court held that courts cannot go beyond the statutory framework and adopt a special, judge-made rule to govern the accrual of tort claims where the would-be plaintiff is a minor.Petitioners alleged that Daniel Heffield sexually abused them as children. Petitioners filed the underlying lawsuit against New Life Community Church, Daniel's employer at the time of the alleged abuse, and other defendants, alleging negligence claims and a respondeat superior claim. Respondents (other than Daniel) moved for summary judgment, arguing that Petitioners' claims were untimely. The trial court entered summary judgment for Respondents, concluding that Petitioners' claims accrued at the time of injury and therefore were untimely. The court of appeal affirmed. On appeal, Petitioners argued that the accrual of their claims were governed by the judge-made delayed accrual rule that the Supreme Court applied in Hearndon v. Graham, 767 So. 2d 1179 (Fla. 2000). The Supreme Court affirmed, holding (1) the statutory framework leaves no room for supplemental common law accrual rules; and (2) the Hearndon decision did not apply to delay the accrual of Petitioners' claims. View "R.R. v. New Life Community Church of CMA, Inc." on Justia Law

Posted in: Personal Injury
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The Supreme Court answered a certified question by holding that a mass shooting committed by Patrick Dell was a single "incident or occurrence" for purposes of Fla. Stat. 768.28(5) and that the cumulative liability for all claims of injury resulting from the incident may not exceed the aggregate cap of $200,000 set forth in section 768.28(5).Dell fatally shot his former wife and four of her children and severely wounded a fifth child. Plaintiffs, the two fathers of the deceased and injured children, sued the Florida Department of Children and Families (DCF) alleging wrongful death and negligence. The trial court granted partial summary judgment for Plaintiffs and determined that each wrongful death or personal injury claim was eligible for the $100,000 per person and $200,000 per claim limitation found in section 768.28(5). The court of appeal reversed, concluding that the claims arose from the same incident of negligence, and therefore, the $200,000 cap per incident or occurrence applied to limit recovery for all claims. The Supreme Court approved of the court of appeal's result, holding that the claims stemming from the mass shooting of Dell's victims were subject to the $200,000 aggregate cap for damages paid by the State, its agencies, or subdivisions. View "Barnett v. State, Department of Financial Services" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Defendant's successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the circuit court properly denied relief.Defendant was found guilty of first-degree murder and was sentenced to death. In his successive postconviction motion, Defendant claimed that he was entitled to relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016), and that the indictment was defective because it failed to include aggravating factors. The circuit court denied relief. The Supreme Court affirmed, holding (1) this Court's decision in State v. Poole, 297 So. 3d 487 (Fla. 2020), foreclosed relief on Defendant's Hurst claims; and (2) Defendant's claim that the indictment was defective was procedurally barred. View "Lott v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court dismissing Petitioner's third successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in dismissing the motion as untimely.Petitioner was convicted of first-degree murder, armed robbery, and armed burglary. Petitioner was sentenced to death. The Supreme Court affirmed the convictions and sentence. Petitioner later filed a third successive motion for postconviction relief, raising a claim of newly discovered evidence. The trial court dismissed the motion as untimely. The Supreme Court affirmed, holding that because Petitioner and his counsel failed to exercise diligence in pursuing the facts on which the claim was predicated, the trial court did not err in dismissing the motion. View "Dillbeck v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court denied the petition filed by Representative Geraldine Thompson seeking to invalidate Governor Ron DeSantis's appointment of Judge Renatha Francis to fill a vacancy in office on the Supreme Court, holding that there was no legal justification for the Court to require a replacement appointment from a new list of candidates rather than the one already before the Governor.In her petition, Thompson argued that the Florida Constitution required Judge Francis to have been a member of the Florida Bar for at least ten years at the time of the appointment, which Judge Francis was not. As a remedy, Thompson asked the Supreme Court to invalidate the appointment, require the judicial nominating commission to certify a new list of candidates, and order the Governor to appoint someone from the new list. The Supreme Court denied relief, holding (1) the Governor did not exceed his authority in making the appointment; and (2) the remedy Thompson sought was not legally available under the circumstances, and the correct remedy - an appointment from the existing list of eligible nominees - would be contrary to Thompson's stated objectives in filing this case. View "Thompson v. DeSantis" on Justia Law

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The Supreme Court concluded that Petitioner's quo warranto petition filed in this case was a frivolous proceeding brought before the Supreme Court by a state prisoner and instructed the Clerk of Court to reject any future filings submitted by Petitioner that are related to two criminal cases unless such filings are signed by a member in good standing of The Florida Bar.Petitioner was convicted in two separate cases of drug-related offenses. Petitioner since filed thirty-four petitions or notices, the majority of which were related to his convictions and sentences in the aforementioned criminal cases. All of the filings were denied, dismissed, or transferred. In this quo warranto petition, Petitioner claimed that the State Attorney for the Twentieth Judicial Circuit failed to acknowledge a habeas petition that he had mailed to her office. The Supreme Court dismissed the petition and concluded that sanctions should be imposed because Petitioner has abused the judicial process and burdened the Supreme Court's limited judicial resources. View "James v. Fox" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the circuit court denying Tina Lasonya Brown's motion to vacate her conviction of first-degree murder and sentence of death under Fla. R. Crim. P. 3.851 and denied Brown's petition for a writ of habeas corpus, holding that Brown was not entitled to relief.As to Brown's postconviction appeal, the Supreme Court held (1) the circuit court did not err in denying Brown's allegations of ineffective assistance of counsel in some respects but erred in denying Brown's allegations of ineffective assistance of counsel in other respects; (2) there was no reasonable probability that bur for trial counsel's deficiencies, individually or cumulatively, the outcome would have been different; (3) the circuit court did not err in denying Brown's claim of newly discovered evidence; and (4) the circuit court did not err in summarily denying Brown's claim that she was not entitled to relief from her death sentence under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). As to Brown's habeas petition, the Supreme Court held that appellate counsel was not ineffective on direct appeal. View "Brown v. State" on Justia Law

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The Supreme Court affirmed the circuit court's order summarily denying Defendant's successive emotion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the circuit court properly denied Defendant's claims.Defendant was convicted of first-degree felony murder, aggravated child abuse, and sexual battery and sentenced to death for first-degree felony murder. Defendant later filed a successive postconviction motion claiming that the State committed Giglio and Brady violations. The circuit court summarily denied the motion. The Supreme Court affirmed, holding that the circuit court did not err in summarily denying Defendant's Giglio claim and properly denied Defendant's Brady claim. View "Davis v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court denying Defendant's fifth successive postconviction motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Defendant was not entitled to postconviction relief.Defendant was convicted of first-degree murder and robbery and sentenced to death. In his fifth successive postconviction motion, Defendant argued that his counsel conceded guilt without his consent and that the error was structural. The trial court dismissed the motion on the grounds that it was untimely and that, even if it had been timely, it was without merit. The Supreme Court affirmed, holding that Defendant did not state a facially sufficient claim. View "Atwater v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court summarily denying Defendant's second successive motion for post conviction relief, holding that Defendant was not entitled to postconviction relief.Defendant was convicted of first-degree felony murder and burglary with an assault. The trial judge imposed the death sentence, and the Supreme Court affirmed. Defendant later filed a second successive motion for postconviction relief under Fla. R. Crim. P. 3.851 claiming that he was entitled to relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016), and Atkins v. Virginia, 536 U.S. 304 (2002). The trial court summarily denied the motion. The Supreme Court affirmed, holding (1) Defendant was not entitled to retroactive Hurst relief; and (2) Defendant's intellectual disability claim was untimely. View "Freeman v. State" on Justia Law

Posted in: Criminal Law