Justia Florida Supreme Court Opinion Summaries

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The Supreme Court denied Petitioner's petition to invoke this Court's discretionary jurisdiction, holding that the Florida Constitution does not authorize the Supreme Court to review cases that "may present federal issues." Petitioner, an inmate, filed a motion for postconviction relief alleging ineffective assistance of counsel. The postconviction court denied the motion, ruling that Petitioner had failed to demonstrate prejudice. The court of appeals affirmed. Petitioner then filed a notice to invoke the Supreme Court's discretionary jurisdiction on the ground that the court of appeal's decision below "expressly and directly conflicts with the decision of another district court of appeal or the Florida Supreme Court." Petitioner's jurisdictional brief, however, did not identify a conflict case but instead stated that the case "may present federal issues." The Supreme Court denied relief, holding that because Petitioner's jurisdictional brief failed to identify a jurisdictional basis for the Court to consider his case, he was not entitled to review. View "Mallet v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court denying in part and dismissing in part Defendant's second successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that Defendant was not entitled to relief on his claim. In his second successive postconviction motion Defendant asserted that newly discovered evidence required that his conviction be overturned, that the State committed Brady and Giglio violations, and that his death sentence was unconstitutional because he was innocent of the murder. The circuit court denied relief. The Supreme Court affirmed, holding (1) all of Defendant's newly discovered evidence claims were either correctly rejected as untimely or based on inadmissible evidence; (2) each of Defendant's Giglio claims failed on the merits; (3) the lower court did not err in declining to take judicial notice of certain records; and (4) the circuit court did not err in summarily rejecting Defendant's claim that he is actually innocent. View "Dailey v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's conviction and death sentence for first-degree murder, holding that Defendant was not entitled to relief on any of his allegations of error. Specifically, the Court held (1) the jury instructions during the penalty phase were sufficient; (2) the trial court did not err in admitting Defendant's letters to a predecessor judge and the elected state attorney; (3) the trial court's findings of the CCP aggravator were supported by competent, substantial evidence; (4) there was no error in the court's analysis of the prior violent felony aggravator; (5) the sentencing order was sufficient; (6) the evidence was sufficient to sustain the murder conviction; and (7) the death sentence was proportionate. View "Rogers v. State" on Justia Law

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Based on Gregory Harris's persistent history of filing pro se petitions that were meritless or otherwise inappropriate for the Supreme Court's review, the Supreme Court held that Harris had abused the judicial process and burdened the Court's resources and that Harris's petition for a writ of habeas corpus filed in this case was a frivolous proceeding. Accordingly, the Court instructed the Clerk of the Court to reject any future pleadings, petitions, motions, documents, or other filings submitted by Harris relating to his criminal convictions for child abuse and grand theft unless such filings were signed by a member in good standing of The Florida Bar. View "Harris v. Inch" on Justia Law

Posted in: Criminal Law
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Based on Donald Williams' persistent history of filing pro se petitions that were meritless or otherwise inappropriate for the Supreme Court's review, the Supreme Court held that Williams had abused the judicial process and burdened the Court's resources and that Williams' petition for a writ of habeas corpus filed in this case was a frivolous proceeding. Accordingly, the Court instructed the Clerk of the Court to reject any future pleadings, petitions, motions, documents, or other filings submitted by Williams relating to his criminal conviction for second-degree murder unless such filings were signed by a member in good standing of The Florida Bar. View "Williams v. Inch" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the postconviction court summarily denying Gary Ray Bowles' successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851 and denied Bowles' petition for a writ of habeas corpus and the motions to stay his execution, holding that Bowles was not entitled to relief. Bowles pleaded guilty to first-degree murder and was sentenced to death. In 2017, Bowles filed a successive postconviction motion, raising an intellectual disability claim for the first time. Bowles filed the final version of this motion after the governor signed his death warrant in 2019. The postconviction court denied the intellectual disability claim as untimely. Bowles appealed and also filed a habeas petition alleging that his execution would constitute cruel and unusual punishment. The Supreme Court affirmed the denial of postconviction relief and denied the habeas petition, holding (1) Bowles' intellectual disability claim was untimely; (2) the postconviction court did not abuse its discretion in denying Bowles' request for certain public records; and (3) because the United States Supreme Court has made clear that capital punishment does not constitute cruel and unusual punishment under the Eighth Amendment, this Court cannot invalidate Bowles' death sentence as cruel and unusual. View "Bowles v. State" on Justia Law

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The Supreme Court quashed the decision of the Third District on the issue of whether a defendant is entitled to a de novo sentencing proceeding after an appellate court determines that the trial court's initial downward departure sentence was not supported by legally sufficient findings, holding that the proper remedy upon reversal of a sentence due to the invalidity of a downward departure is resentencing de novo. Defendant pled guilty to four offenses and was placed on probation. The trial court subsequently revoked Defendant's probation and imposed a downward departure from what otherwise would have been the lowest permissible sentence under the Criminal Punishment Code (CPC). The Third District concluded that the departure was invalid and remanded for "resentencing within the sentencing guidelines." The Supreme Court quashed the Third District's decision, holding that on remand for resentencing due to the substantive invalidity of a downward departure, the trial court is permitted to impose a downward departure as long as the departure comports with the principles and criteria of the CPC. View "Shine v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the Florida Public Service Commission approving a request made by Florida Power and Light (FPL) for the recovery of costs through base rates for eight solar energy centers (the SoBRA projects), holding that the Commission's findings regarding the cost-effectiveness of the SoBRA projects were based on competent, substantial evidence. In granting FPL's request, the Commission concluded that the SoBRA projects comported with the terms of a settlement agreement providing for recovery of costs through base rates and that the projects were cost effective. The Supreme Court affirmed, holding (1) by failing to object at the time that the settlement agreement was before the Commission and by failing to appeal the settlement order, Appellant waived its right to challenge the provisions in the settlement agreement related to the requirements and procedures for cost recovery of the SoBRA projects; and (2) the SoBRA projects met the terms set forth in the settlement agreement for cost recovery. View "Florida Industrial Power Users Group v. Brown" on Justia Law

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The Supreme Court held that through persistent filing of nonmeritorious requests for relief, Mark Jackson had abused the judicial process and, accordingly, directed the Clerk of Court to reject any future pleadings, documents, or other requests for relief submitted by Jackson unless such filings were signed by a member in good standing of The Florida Bar. Jackson - a pro se litigant - filed a petition to invoke the Supreme Court's discretionary jurisdiction. The Court denied Jackson's petition but expressly reserved jurisdiction to pursue possible sanctions against him. While the case was pending, Jackson filed several motions that were frivolous, without merit, or sought relief previously denied. The Supreme Court concluded that a sanction was necessary because, if not restrained, Jackson would continue to burden the Court with frivolous and meritless filings. View "Jackson v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court ordered that the Clerk of Court reject any future pleadings, petitions, motions, documents, or other filings submitted by Larry R. Wetzel that were related to his criminal case, holding that that Wetzel has abused the judicial process and burdened the Court's limited judicial resources. Wetzel was charged with five counts of filing a false statement against real or personal property. Wetzel filed five pro se petitions with the Supreme Court seeking relief related to those criminal charges, each of which was accompanied by a plethora of rambling documents. Two of the petitions were voluntarily dismissed by Wetzel but the remainder were dismissed as unauthorized. Based on Wetzel's vexatious filing history, the Supreme Court issued an order directing him to show cause why he should not be prohibited from filing any further pro se documents in the Court related to his criminal case. Upon consideration of Wetzel's response, the Supreme Court concluded that he failed to show cause why sanctions should not be imposed. View "Wetzel v. State" on Justia Law

Posted in: Criminal Law