Justia Florida Supreme Court Opinion Summaries

In 2010, the appellant, her sixteen-year-old daughter, and a third individual kidnapped Audreanna Zimmerman, beat her with a crowbar, used a stun gun on her, and set her on fire. Zimmerman survived long enough to identify her attackers but died from her injuries sixteen days later. At trial, testimony by co-perpetrator Heather Lee, the appellant’s cellmate Corie Doyle, and a thirteen-year-old eyewitness placed the appellant as the primary aggressor and instigator. Forensic evidence further linked the appellant to the crime. The appellant was convicted of first-degree murder and sentenced to death after the jury unanimously recommended that sentence. The trial court found several aggravating factors, including that the murder was heinous, atrocious, or cruel, and that it was committed in a cold, calculated, and premeditated manner.Following direct appeal, the Supreme Court of Florida affirmed the conviction and sentence. The appellant later sought postconviction relief in the Circuit Court for Escambia County, alleging ineffective assistance of counsel and presenting newly discovered evidence primarily related to Lee’s credibility. The postconviction court, and subsequently the Supreme Court of Florida, denied these claims, finding that additional impeachment of Lee was unlikely to yield a lesser sentence due to the weight of other evidence against the appellant.In a successive motion, the appellant presented new claims based on Doyle’s recantation of her trial testimony and additional mitigation evidence. After an evidentiary hearing, the postconviction court found the new evidence untimely, not credible, and unlikely to produce a different penalty, and denied the motion and a related public records request.On appeal, the Supreme Court of Florida affirmed the postconviction court’s rulings. It held that Doyle’s recantation was not credible and, even if it were, the new evidence would not probably result in a lesser sentence at a new penalty phase. View "Brown v. State of Florida" on Justia Law

A seventeen-year-old individual planned and carried out a violent attack resulting in the death of one person and serious injuries to two others. After purchasing a knife, he attended a dinner and sleepover with friends. Late at night, he attacked and fatally stabbed one victim, then proceeded to injure two others. The police apprehended him at the scene. He was charged with first-degree murder and two counts of attempted first-degree murder. The jury convicted him on all counts. Because he was a juvenile at the time, a separate sentencing hearing was held to consider mitigating factors under Florida law.The Circuit Court for Palm Beach County sentenced him to life without parole (LWOP) for each count, with the two attempted murder sentences running concurrently but consecutively to the murder sentence. The court announced that he would be eligible for judicial review after serving 25 years on the murder conviction, and again after serving another 25 years on the consecutive sentences for attempted murder. The defendant challenged his sentence, arguing that consecutive LWOP sentences for offenses committed in a single episode violated the Eighth Amendment, relying on Graham v. Florida. The Circuit Court denied relief, and on direct appeal, the Fourth District Court of Appeal upheld the sentences, holding that the structure provided a meaningful opportunity for release consistent with constitutional requirements. The Fourth District certified conflict with the Second District Court of Appeal’s decision in Mack v. State, which had found such consecutive sentences unconstitutional.The Supreme Court of Florida reviewed the case and held that the Eighth Amendment’s requirement of a “meaningful opportunity for release” from Graham v. Florida does not apply to juveniles convicted of homicide offenses. Instead, sentencing for juvenile homicide offenders is governed by Miller v. Alabama and Jones v. Mississippi, requiring individualized sentencing but permitting discretionary LWOP. The Court approved the Fourth District’s result, disapproved Mack, and upheld the sentences. View "Johnson v. State of Florida" on Justia Law

A special independent recreation district was established in 2018 to manage and improve recreational facilities within a residential community, including a country club and golf course. In 2019, the district issued $24 million in bonds to purchase and maintain these facilities, pursuant to a referendum and a master trust indenture. A provision in the first supplemental indenture for the 2019 bonds included bracketed language suggesting that no further bonds would be issued, except for certain purposes. However, in 2023, the district's Board proposed a new $21 million bond issue to fund additional improvements, which was approved by a majority of residents in a 2024 referendum. The Board subsequently amended the 2019 indenture, clarifying that the bracketed language was never formally adopted and authorized the new bonds.In the Twelfth Judicial Circuit Court for Manatee County, a resident who moved into the district in 2021 challenged the district’s authority to issue the new bonds, arguing that the language in the 2019 indenture barred further bond issues, and questioned whether the special assessments to repay the bonds provided sufficient special benefit to the properties. He also raised due process concerns about the proceedings. The circuit court admitted evidence, including expert testimony on property value benefits, and found for the district, validating the 2024 bond issue. The court found the district had authority to issue the bonds and that the special benefits exceeded the debt burden.On appeal, the Supreme Court of Florida affirmed the circuit court’s judgment. The Court held that the district had statutory and referendum-based authority to issue the 2024 bonds, that the Board properly clarified and amended the indenture, and that legislative findings and expert testimony supported the conclusion that the special assessments conferred a special benefit. The Court also found no due process violation. View "Matt v. State of Florida" on Justia Law

A woman was shopping at a grocery store in Florida when she slipped on spilled dish soap and fell. Security footage showed that after the fall, she continued shopping and later purchased champagne. She later sued the store for premises liability, alleging significant physical injuries that she claimed severely limited her activities, including being unable to lift her children, bend, or play in the pool. During discovery, she repeated these claims in interrogatory answers and deposition testimony. The store hired a private investigator, who recorded her performing many of the activities she claimed she could not do, such as lifting her children, bending, carrying groceries, and playing in the pool.The Circuit Court for Broward County held an evidentiary hearing, after which it found by clear and convincing evidence that the woman intentionally and repeatedly lied about her limitations and that her testimony was not credible. The court found that her fraudulent conduct “comprehensively infected the integrity” of the case and dismissed her entire complaint with prejudice as a sanction for fraud on the court.The Fourth District Court of Appeal reviewed the dismissal. Applying what it termed a “more stringent abuse of discretion standard” to the sanction, it affirmed the finding of fraud but reversed in part, holding that only the claims dependent on her subjective testimony (pain and suffering, lost wages) should be dismissed, while her claim for medical expenses should be reinstated.The Supreme Court of Florida held that the correct standard of appellate review involves reviewing factual findings for competent, substantial evidence, legal conclusions de novo, and the choice of sanction for abuse of discretion—not a heightened or “more stringent” abuse of discretion standard. The Court quashed the Fourth District’s decision, reinstated the trial court’s order dismissing the entire complaint with prejudice, and disapproved conflicting case law to the extent it applied a different standard. View "Publix Supermarkets, Inc. v. Goga" on Justia Law

A husband filed a petition to dissolve his marriage in 2018, and the trial court entered an uncontested judgment of dissolution nine months later but reserved ruling on issues including equitable distribution of marital property. The court ultimately resolved the contested distribution in 2022, valuing the marital assets as of the date of the initial petition. The former wife requested prejudgment interest on her share of the assets from the date of the petition to the actual distribution, but the trial court denied this, finding it inequitable to charge the former husband for delays mainly due to the pandemic.The former wife appealed the denial, among other issues, to the Third District Court of Appeal. The appellate court found several errors, including the trial court’s failure to support its denial of attorney’s fees with factual findings and its lack of evidentiary support for denying prejudgment interest. The Third District held that the trial court’s stated basis for denying prejudgment interest was inconsistent with the underlying purpose of such awards and noted this conflicted with the First District Court of Appeal’s decision in Iarussi v. Iarussi, which categorically prohibited prejudgment interest in equitable distribution.The Supreme Court of Florida reviewed the case to resolve the conflict between the district courts. It held that a trial court has discretionary authority to award prejudgment interest as an equitable remedy under section 61.075, Florida Statutes, when distributing marital property. The Court emphasized that such awards are not automatic but depend on the facts of each case and the trial court’s discretion to achieve equity between the parties. The Court approved the Third District’s decision and disapproved the First District’s contrary holding in Iarussi. The case was remanded for further proceedings consistent with this opinion. View "Stewart v. Vindel" on Justia Law

A general manager at a car rental business located within a hotel near Orlando International Airport was shot multiple times by an unknown assailant while moving from an indoor kiosk to an outside office late at night. The attack, which did not include robbery, was recorded on surveillance video. The manager had been working an unusual shift to train new employees after firing others, and often carried cash and rental agreements between locations. The motive and identity of the assailant remain unknown. The manager survived and sought workers’ compensation benefits, arguing the attack was related to risks inherent in his employment, such as carrying cash late at night and the potential for retaliation from recently terminated employees.A Judge of Compensation Claims (JCC) found the injuries compensable, relying in part on precedent from the Supreme Court of Florida and determining that the employment and work environment substantially increased the risk of attack. The JCC found that the risk was more likely related to work duties or job-related issues, rather than a purely personal dispute. Normandy Insurance Company appealed, arguing that the injuries did not arise out of employment as required under Florida’s workers’ compensation statute.The First District Court of Appeal vacated the JCC’s order, holding that the injuries did not arise out of the “work performed,” narrowly interpreting the statutory language to require that the specific work activity at the time of injury must itself cause the injury. The Supreme Court of Florida reviewed the case, rejected the First District’s narrow interpretation, and clarified that an employee may receive compensation for injuries from a third-party assault if the claimant can establish that the employment or work environment exposed them to an increased risk of such injury. The Supreme Court quashed the First District’s decision and remanded for further proceedings using the correct legal standard. View "Bouayad v. Normandy Insurance Company" on Justia Law

In 1981, Dennis Sochor murdered Patricia Gifford after she refused his sexual advances; her body was never recovered. Sochor, who had fled the state after seeing himself on television, was apprehended in Georgia five years later and confessed multiple times to the crime. At trial, the jury found him guilty of kidnapping and first-degree murder, recommending a death sentence by a 10-2 vote. The trial court imposed the death penalty, finding four aggravating factors and no mitigating circumstances.On direct appeal, the Supreme Court of Florida affirmed Sochor’s conviction and sentence but was later instructed by the United States Supreme Court to conduct a harmless error analysis regarding one aggravator. After doing so, the Florida court again affirmed. Sochor's conviction and sentence became final in 1993. Since then, he has pursued numerous postconviction challenges in both state and federal courts, all unsuccessful. After the Governor signed a death warrant in June 2026, Sochor filed a sixth successive postconviction motion in the Circuit Court for Broward County, raising two claims: a Brady/Giglio violation concerning a 2022 letter to his brother, and a facial challenge to Florida’s lethal injection protocol. The circuit court summarily denied both claims as untimely, procedurally barred, and without merit.The Supreme Court of Florida reviewed the summary denial de novo and affirmed the circuit court’s ruling. The court held that Sochor’s method-of-execution claim was untimely because the evidence on which it relied had been discoverable since at least 2017, and that the claim was meritless because similar challenges to Florida’s lethal injection protocol had repeatedly been rejected. The court also denied Sochor’s motion for a stay of execution and declined to hold oral argument or entertain a motion for rehearing. View "Sochor v. State" on Justia Law

James Aren Duckett, a police officer, was convicted nearly forty years ago of the sexual battery and first-degree murder of eleven-year-old Teresa McAbee. On the night of May 11, 1987, Duckett was the only officer on patrol in Mascotte, Florida and was the last person seen with Teresa in his patrol car. Circumstantial evidence, including tire tracks and comingled fingerprints from the victim and Duckett on his patrol car, implicated him. Teresa’s body was found the next morning, and a medical examiner determined she had been sexually assaulted, strangled, and drowned. The jury found Duckett guilty and recommended a death sentence, which the trial court imposed after finding aggravating circumstances.Duckett’s conviction and sentence were affirmed by the Supreme Court of Florida in 1990. He subsequently sought postconviction relief several times in both state and federal courts, but all motions and petitions were denied. After a death warrant was signed in 2026, Duckett filed for postconviction DNA testing, which the circuit court granted. He then filed his fifth successive postconviction motion under Rule 3.851, raising claims of actual innocence and alleged constitutional violations. Before DNA testing results were available, the circuit court summarily denied his motion and declined to stay his execution. Duckett appealed and requested a stay, which the Supreme Court of Florida granted to allow completion of DNA testing.The Supreme Court of Florida reviewed the circuit court’s summary denial de novo. Duckett’s DNA testing results were found inconclusive, and his claims of actual innocence and constitutional violations lacked merit under Florida law. The Court affirmed the circuit court’s denial of Duckett’s fifth successive postconviction motion, denied his habeas petition, and lifted the stay of execution. No rehearing would be considered, and the mandate issued immediately. View "Duckett v. State" on Justia Law

A married couple contracted with a design company to oversee renovations to their vacation rental property. After the company ended its work prematurely, the couple sued for breach of contract and unjust enrichment, and the company countersued for breach of contract and tortious interference with a business relationship. Before trial, the couple submitted a proposal for settlement to the company, offering to resolve all claims for a single lump sum. The company rejected this proposal, and after trial, the jury awarded the couple damages on their breach of contract claim. The company received nothing on its counterclaims.Following the verdict, the couple moved for attorney’s fees under section 768.79, Florida Statutes, which allows fees when a plaintiff’s settlement proposal is rejected and the plaintiff prevails by a sufficient margin. The Circuit Court denied their motion, finding the proposal for settlement invalid because it did not allocate the settlement amount separately to each plaintiff, as required by Florida Rule of Civil Procedure 1.442(c)(3). On appeal, the Fourth District Court of Appeal reversed, holding that apportionment was not required for a joint proposal involving a unified, single claim.The Supreme Court of Florida reviewed the case because the Fourth District’s decision conflicted with the Second District Court of Appeal’s decision in Cobb v. Durando. The Supreme Court held that Rule 1.442(c)(3) requires apportionment for all joint proposals, even those involving a single, unified claim. The Court quashed the Fourth District's decision, approved the Second District’s approach in Cobb, and remanded the case for further proceedings. The holding requires strict compliance with the apportionment requirement in joint proposals for settlement under Florida law. View "Trace Elements, Inc. v. Mackensen" on Justia Law

The appellant was convicted of first-degree murder and sentenced to death after the body of Karen Nieradka was found in construction debris several weeks after her disappearance. He was arrested while driving Nieradka’s vehicle and made various conflicting statements to law enforcement. At trial, several jailhouse witnesses, including Edward Cottrell and Harvey Duranseau, testified that the appellant made incriminating statements. He was convicted and sentenced to death, with both his conviction and sentence affirmed on direct appeal. Subsequent postconviction motions were denied.After filing a successive motion for postconviction relief in the Circuit Court for Pinellas County, the appellant presented affidavits from Cottrell and Duranseau alleging that they were coached by law enforcement and offered benefits in exchange for their testimony. Additional affidavits claimed law enforcement fabricated police reports. The postconviction court held an evidentiary hearing, hearing testimony from both jailhouse witnesses and law enforcement. The postconviction court found that the jailhouse witnesses were not credible and denied all relief, including rehearing.On appeal, the Supreme Court of Florida reviewed four claims: violations under Brady v. Maryland and Giglio v. United States, improper elicitation of statements under Massiah v. United States, and newly discovered evidence. The Court deferred to the postconviction court’s credibility determinations, finding competent, substantial evidence supported those findings. The Court held that the appellant failed to establish suppression of material exculpatory evidence, the use of false testimony, the existence of state agents violating his right to counsel, or newly discovered evidence warranting a new trial. The Supreme Court of Florida affirmed the Circuit Court’s denial of the successive motion for postconviction relief. View "Rhodes v. State of Florida" on Justia Law