Justia Florida Supreme Court Opinion Summaries

A dispute arose among residents of a Palm Beach community after Harold Peerenboom sued Isaac and Laura Perlmutter for defamation, alleging they orchestrated a hate mail campaign. The Perlmutters counterclaimed for various torts, including defamation and invasion of privacy, and later sought to amend their counterclaims to add punitive damages against Peerenboom, his attorney William Douberley, and Douberley’s employer, Federal Insurance Company. The Perlmutters alleged that Peerenboom and Douberley improperly collected their DNA and manipulated evidence to falsely implicate them, while Federal Insurance was accused of inadequate oversight.After reviewing the Perlmutters’ evidentiary submission and hearing arguments, the Circuit Court granted their motion to amend and add punitive damages claims. Peerenboom, Douberley, and Federal Insurance appealed. The Fourth District Court of Appeal, sitting en banc, reversed the trial court, holding that the trial court should have denied the motion because the evidence could not support a finding of intentional misconduct or gross negligence by clear and convincing evidence. The Fourth District required that, at the pleading stage, the court must determine whether a reasonable jury could find punitive damages warranted by clear and convincing evidence, considering all evidence from both sides.On review, the Supreme Court of Florida held that, under section 768.72(1), Florida Statutes, the trial court at the pleading stage should only consider the evidence proffered by the claimant and not opposing evidence. The Court further held that the clear and convincing evidence standard does not apply at this stage; instead, the trial court must determine only whether a reasonable person could conclude, based on the claimant’s evidence, that the defendant’s conduct could meet the statutory standard for punitive damages. The court quashed the Fourth District’s decision and remanded for further proceedings consistent with this holding. View "Perlmutter v. Federal Insurance Company" on Justia Law

A utility company serving multiple Florida counties sought approval from the Florida Public Service Commission for a four-year rate plan. As part of its petition, the company requested approval for two accounting measures: the Reserve Surplus Amortization Mechanism-Adjusted Depreciation Parameters (RSAM-ADP) and the Reserve Surplus Amortization Mechanism (RSAM). The RSAM-ADP would result in a reserve surplus, which the RSAM aimed to address. Additionally, the continued use of an acquisition adjustment related to a prior corporate purchase became an issue during the proceedings.The Public Service Commission received and considered various depreciation proposals from both the utility and the Office of Public Counsel (OPC), as well as testimony regarding the appropriateness and impact of the RSAM-ADP and RSAM. The Commission approved the RSAM-ADP, recognizing it would result in a reserve surplus, and then approved the RSAM as a corrective measure. The Commission also allowed the continued amortization of the acquisition adjustment until the utility’s next rate case. OPC filed a motion for reconsideration, which was denied, and then appealed the Commission’s decisions to the Supreme Court of Florida.The Supreme Court of Florida reviewed whether the Commission’s actions were consistent with its rules, policy, and prior practice, and whether its decisions were supported by competent, substantial evidence. The Court held that the Commission’s approval of the RSAM-ADP and RSAM was not inconsistent with the applicable depreciation rule, did not violate official policy or prior practice, and was supported by substantial evidence. The Court also found that the continuation of the acquisition adjustment was neither contrary to official policy nor lacking evidentiary support. The Supreme Court of Florida affirmed the Commission’s final and clarifying orders. View "Citizens of the State of Florida v. Florida Public Service Commission" on Justia Law

An employee in Florida was terminated by his employer after raising several workplace safety concerns. The employer stated that the termination was due to the employee's use of racially disparaging language, following a series of disciplinary actions. The employee subsequently filed suit, alleging that his dismissal was in retaliation for objecting to what he believed were illegal safety practices, in violation of Florida’s private sector Whistle-Blower’s Act.After discovery, the employer moved for summary judgment in the Circuit Court, arguing that the employee failed to show he had objected to actual violations of law, rule, or regulation. The employee countered that it was sufficient to show he had a good faith, objectively reasonable belief that the practices he objected to were illegal. The trial court sided with the employer, holding that the statute required objection to an actual, not suspected, violation. The First District Court of Appeal affirmed, aligning with decisions from the Second and Fifth Districts and certifying conflict with the Fourth District, which had adopted a “good faith, objectively reasonable belief” standard.The Supreme Court of Florida reviewed the case to resolve this conflict among the district courts of appeal. The Court held that, under section 448.103 and section 448.102(3), Florida Statutes, an employee must prove by a preponderance of the evidence that the employer’s activity, policy, or practice to which the employee objected is, by definition, in violation of law. It is not enough for the employee simply to have a subjective, good faith, or objectively reasonable belief that the employer’s conduct was illegal. The Court approved the result reached by the First District but clarified the applicable legal standard. View "Gessner v. Southern Company" on Justia Law

In this case, the appellant was convicted and sentenced to death for the 1996 murder of a five-month-old child in Jacksonville, Florida. The appellant, who was living with the victim’s mother at the time, initially claimed the child had been abducted, prompting an extensive police search. He later confessed to killing the child and disposing of her body in a pond. At trial, the appellant’s explanations about the cause of death were inconsistent with the medical evidence, which showed multiple fatal head injuries. The jury convicted him of first-degree murder and aggravated child abuse, and he was sentenced to death based partly on aggravating factors including a prior conviction for child abuse.After his conviction and sentence were affirmed by the Supreme Court of Florida on direct appeal, the appellant pursued multiple rounds of postconviction relief in both state and federal courts, all of which were unsuccessful. Most recently, following the signing of a death warrant, the appellant filed a third successive postconviction motion in the Circuit Court for the Fourth Judicial Circuit. He argued that Florida’s lethal injection protocol was unconstitutional as applied to him and on its face, that the short period between the warrant and execution deprived him of due process, and that he was wrongly denied additional public records. The circuit court summarily denied all claims.The Supreme Court of Florida reviewed the circuit court’s summary denial de novo and affirmed. The court held that the as-applied and facial Eighth Amendment challenges to Florida’s lethal injection protocol were both untimely and meritless. The court also found no due process violation in the expedited warrant litigation schedule and no abuse of discretion in denying the requests for additional public records. The appellant’s motion for a stay of execution was denied, and the summary denials of postconviction relief and records requests were affirmed. View "Lukehart v. State" on Justia Law

In this case, the defendant was convicted of the 2008 murder of Nimoy Johnson and related offenses following a complex series of events involving armed kidnapping and robbery. After staying with relatives near Johnson’s home, the defendant was implicated in a burglary of Johnson’s residence. Tensions arose between Johnson and the defendant’s relatives, but matters seemed resolved. About a week later, the defendant was present at Johnson’s home when several women arrived. The defendant, armed and masked, held the women and Johnson at gunpoint, ordered them to be restrained, and later shot Johnson in the head while he was bound, before fleeing in one of the women’s vehicles. The defendant was apprehended shortly thereafter, and physical evidence linked him to the crime scene and the murder weapon.At trial in the Circuit Court for Broward County, a jury found the defendant guilty of first-degree murder, multiple counts of armed kidnapping, and armed robbery. The penalty phase resulted in a seven to five jury recommendation for death. The court found four statutory aggravators and several nonstatutory mitigators, but determined the aggravators outweighed the mitigators and sentenced the defendant to death, with additional life sentences on the other counts. On direct appeal, the Supreme Court of Florida affirmed the convictions and sentences, finding any errors to be harmless.Subsequently, the defendant filed a motion for postconviction relief and a petition for writ of habeas corpus, raising claims of ineffective assistance of counsel, errors under Hurst v. Florida and related cases, Brady and Giglio violations, and newly discovered evidence. After proceedings including an evidentiary hearing, the circuit court denied all claims. The Supreme Court of Florida affirmed this denial, holding that counsel’s performance was not deficient, that there was no prejudice, and that none of the defendant’s legal or constitutional claims merited relief. The court also denied habeas relief on all grounds. View "Wilcox v. State of Florida" on Justia Law

Richard Knight was convicted of the first-degree murders of Odessia Stephens and her four-year-old daughter, Hanessia Mullings, with evidence including Knight’s presence at the scene, forensic findings tying him to the crime, and his confession to a fellow inmate. After a jury unanimously recommended the death penalty for both murders, the trial court imposed two death sentences, finding multiple aggravating factors and limited nonstatutory mitigation.On direct appeal, the Supreme Court of Florida affirmed Knight’s convictions and sentences. Subsequent postconviction and habeas proceedings in both state and federal courts were unsuccessful. After the Governor signed Knight’s death warrant, Knight filed a successive postconviction motion in the Circuit Court for Broward County, raising three claims: that unidentified fingerprint evidence constituted newly discovered evidence, that Florida’s lethal injection protocol was unconstitutional, and that the expedited death warrant process deprived him of due process. The circuit court summarily denied all claims and related motions.The Supreme Court of Florida reviewed the summary denial de novo and affirmed. The court held that the unidentified fingerprint claim was untimely, procedurally barred, and without merit, as the evidence was known at trial and did not undermine the case against Knight. The lethal injection claim was also found untimely, procedurally barred, and legally insufficient, as Knight failed to show a substantial risk of harm or propose a feasible alternative method. Lastly, the court rejected the due process claim, finding that Knight received adequate notice and opportunity to be heard. The court denied the request for a stay of execution, and ordered that no oral argument or rehearing would be permitted, with the mandate to issue immediately. View "Knight v. State" on Justia Law

Marcus Roland Maye was convicted of robbery with a deadly weapon in May 2002 and received a mandatory life sentence under Florida’s Prison Releasee Reoffender (PRR) statute. He later filed a motion under Florida Rule of Criminal Procedure 3.800(a), arguing that the procedures of the PRR statute were unconstitutional. Specifically, he claimed that the statute allowed a judge, rather than a jury, to make findings that exposed him to a mandatory minimum sentence, in violation of the rules set out in Apprendi v. New Jersey and Alleyne v. United States.The State opposed Maye’s motion, contending that rule 3.800(a) was not the proper procedural mechanism to challenge a statute's constitutionality and that existing district court precedent foreclosed his claim. The circuit court, bound by precedent holding section 775.082(9) constitutional, denied the motion. On appeal, the Sixth District Court of Appeal affirmed the denial, citing the same precedent.Upon review, the Supreme Court of Florida approved the Sixth District’s result but based its decision on a different ground. The court held that claims of error under Apprendi and its progeny (such as Alleyne) are not cognizable under rule 3.800(a) because those claims are subject to harmless error review and do not constitute “illegal sentences” as contemplated by the rule. The court receded from its earlier decision in Plott v. State, which had allowed such claims to be raised under rule 3.800(a). Accordingly, the Supreme Court of Florida ruled that Maye’s Apprendi claim could not be raised in a rule 3.800(a) motion and affirmed the result below on that basis. View "Maye v. State of Florida" on Justia Law

A prisoner on death row sought access to DNA testing data generated by a private laboratory from evidence collected in 1987, specifically a swab from the victim’s underwear containing sperm cells. This sample had previously been considered unsuitable for conclusive DNA testing due to deterioration and limited material, but the prisoner argued that new technology—Single Nucleotide Polymorphism (SNP) testing—could yield more reliable results. Because the Florida Department of Law Enforcement (FDLE) lacked the capacity for SNP testing, the sample was tested by a private lab, DNA Labs International, Inc. The resulting report concluded the DNA was not suitable for genealogical or phenotypic analysis, and was labeled “inconclusive.” However, underlying data from the SNP testing existed, and FDLE suggested that a qualified expert might be able to conduct further statistical analysis using this data.The Circuit Court for Lake County granted the prisoner’s motion for DNA testing, but allowed the State to control the process. After the private lab’s inconclusive report, the prisoner requested the underlying data and information about the lab’s protocols, arguing that further analysis could exonerate him. The circuit court denied these requests, finding that the prisoner had not shown how the data would be exonerating and that information about the lab’s protocols was not relevant to any postconviction claim.On appeal, the Supreme Court of Florida reversed the circuit court’s denial of the request for the underlying DNA testing data, holding that the prisoner was entitled to the complete testing results, including the data necessary for statistical analysis by an expert. The court reasoned that such data is part of the “results” required by statute and rule to be disclosed. However, the Supreme Court affirmed the denial of the request for information about the lab’s testing process and protocols, as the prisoner had not shown its relevance to a postconviction claim. The case was remanded to provide the data and for further proceedings if necessary. View "Duckett v. State of Florida" on Justia Law

A man convicted of capital murder and sentenced to death sought public records from various state agencies related to Florida’s lethal injection protocol and communications between government entities regarding his execution. He first filed a motion for these records before his death warrant was signed and then submitted an additional request after the warrant was issued. He argued that the records were necessary to support a potential claim that the method of execution would violate his constitutional rights, and that communications between agencies might reveal improper conduct or motives regarding the timing of his execution.The Circuit Court denied both his pre- and post-warrant public records motions, as well as a motion for rehearing and an in camera review of the requested records. The court also denied his motion for an extension of time to file a successive postconviction motion, though he was initially granted some additional time. Despite these denials, the man did not file a successive postconviction motion. He then petitioned the Supreme Court of Florida for relief, arguing that the denials infringed on his rights to due process, equal protection, and access to the courts.The Supreme Court of Florida treated his appeal as a petition for review of a nonfinal discovery order under Florida Rule of Appellate Procedure 9.142(c) and denied it. The Court held that the circuit court did not depart from the essential requirements of law because the requested records were not tied to a colorable claim for postconviction relief, but rather constituted a prohibited fishing expedition. The Court further denied his requests for habeas corpus and oral argument, and dismissed the appeal concerning the denied extension of time. The main holding is that public records requests in capital postconviction proceedings must be connected to a colorable claim for relief. View "Willacy v. State" on Justia Law

A man was charged with seven serious crimes, including multiple counts of armed sexual battery, kidnapping, and aggravated battery. According to the record, he picked up a woman, drove her to a parking lot, and forcibly compelled her to engage in several sexual acts under threat of violence, using a firearm. He further forced her to different locations, continued the assaults, and recorded some of the acts. The victim eventually escaped and alerted law enforcement, leading to the man's arrest.The defendant entered no contest pleas to all seven charges. At sentencing in the Circuit Court, he requested a 25-year sentence, which would have been a downward departure from the minimum sentence indicated by the guidelines. The court declined, citing the severity of the crimes, and imposed six life sentences and one 15-year sentence. The defendant appealed, and the Florida Fourth District Court of Appeal found sentencing errors, ordering the trial court to correct the scoresheet, remove certain designations and mandatory minimums, reconsider the request for downward departure, and resentence him on two counts.On remand, before resentencing, the defendant moved to withdraw his pleas, invoking Florida Rule of Criminal Procedure 3.170(f), which allows plea withdrawal for good cause before a sentence. The trial court denied the motion and reimposed the sentences. The Fourth District Court of Appeal affirmed, rejecting the argument that Rule 3.170(f) applies during resentencing after an appellate vacatur, and certified conflict with a contrary decision of the Second District Court of Appeal.The Supreme Court of Florida held that Rule 3.170(f)'s good-cause standard for plea withdrawal does not apply during post-appeal resentencing proceedings. The court approved the Fourth District’s decision and disapproved the Second District’s contrary position. View "Saffold v. State of Florida" on Justia Law