Justia Florida Supreme Court Opinion Summaries

Articles Posted in Civil Rights
by
The Supreme Court affirmed the order of the circuit court denying in part Marvin Cannon's initial postconviction motion filed pursuant to Fla. R. Crim. P. 3.851 and denied Cannon's petition for writ of habeas corpus, holding that Cannon was not entitled to relief on his claims. Cannon was convicted of first-degree murder and other crimes and sentenced to death. Cannon later filed his initial motion for postconviction relief, asserting that he was entitled to resentencing under Hurst v. State, 202 So. 3d 40 (Fla. 2016), that counsel was ineffective, and that the Department of Corrections' website reflected he was still serving a fifteen-year sentence for attempted robbery even though that conviction was vacated on direct appeal. The trial court agreed with Cannon's Hurst claim and vacated his death sentence but denied the remaining claims. The Supreme Court affirmed, holding that Cannon was not denied constitutionally effective assistance of counsel and that the postconviction court properly denied Cannon's second claim. In his habeas petition, Cannon alleged ineffective assistance of appellate counsel. The Supreme Court denied the petition, holding that appellate counsel was not ineffective for failing to raise a procedurally barred claim. View "Cannon v. State" on Justia Law

by
The Supreme Court quashed the decision of the First District Court of Appeal vacating Defendant's sentence and remanding for resentencing under the prior version of Fla. Stat. 775.082(1), which could have resulted in reimposition of Defendant's sentence without any findings by a jury or the trial court, holding that the proper remedy for harmful error resulting from the court, not the jury finding the fact of dangerousness under section 775.082(1) is to remand for resentencing. In Brown v. State, 260 So. 3d 147, 150 (Fla. 2018), the Supreme Court held that the portion of section 775.082(10) requiring the court, not the jury, to find the fact of dangerousness to the public necessary to increase the statutory maximum nonstate prison sanction violated the Sixth Amendment. At issue in this case was the proper remedy for harmful error resulting from the court finding the fact of dangerousness under the statute. The First District held that statutory revival was the proper remedy. The Supreme Court quashed the First District's decision, holding that the proper remedy is to remand for resentencing with instructions to either impose a nonstate sanction of up to one year in county jail or empanel a jury to make the determination of dangerousness, if the State so requests. View "Gaymon v. State" on Justia Law

by
The Supreme Court affirmed in part and reversed in part the trial court's judgment ordering a new penalty phase proceeding after finding Defendant was entitled to relief under Hurst v. State, 202 So. 3d 40 (Fla. 2016), and rejecting Defendant's guilt-phase claim, holding that this Court must partially recede from Hurst. The jury in Defendant's case recommended death by a vote of eleven to one after unanimously finding that, during the course of the first-degree murder, Defendant committed related crimes. Defendant later filed his postconviction motion alleging that counsel was ineffective for conceding that Defendant committed the nonhomicide offenses for which he was convicted and that Defendant was entitled to resentencing because the jury did not make the findings required by Hurst. The trial court denied Defendant's ineffective assistance of counsel claim but vacated Defendant's death sentence pursuant to Hurst. The Supreme Court reversed in part, holding (1) this Court recedes from Hurst except to the extent it requires a jury unanimously to find the existence of a statutory aggravating circumstance; and (2) under a correct understanding of Hurst v. Florida, 136 S. Ct. 616 (2016), the requirement that a jury unanimously find a statutory aggravating circumstance beyond a reasonable doubt was satisfied in this case. View "State v. Poole" on Justia Law

by
The Supreme Court affirmed the order of the circuit court denying Appellant's third amended motion to vacate his conviction of first-degree murder and sentence of death filed pursuant to Fla. R. Crim. P. 3.851 and denied Appellant's petition for a writ of habeas corpus, holding that Appellant was not entitled to relief. Appellant was convicted of first-degree murder and sentenced to death. This appeal concerned Appellant's second amended motion for postconviction relief. The postconviction court noted that Appellant was entitled to a new penalty phase pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016) but denied the guilt-phase claims. The majority of the claims presented in Appellant's appeal alleged ineffective assistance of trial counsel. The Supreme Court denied the claims and affirmed the order of the postconviction court. The Court also denied Appellant's petition for writ of habeas corpus, holding that Appellant's claim that comments made by the prosecutor tapped into racial stereotypes was procedurally barred and that Appellant's claim of ineffective assistance of appellate counsel also failed. View "Martin v. State" on Justia Law

by
The Supreme Court affirmed the denial of Sparre's postconviction motion to vacate his conviction of first-degree murder and sentence of death filed under Fla. R. Crim. P. 3.851 and denied his petition for writ of habeas corpus, holding that Sparre was not entitled to relief. As to Sparre's appeal from the denial of his postconviction motion, the Supreme Court held (1) trial counsel was not ineffective, despite two instances in which counsel was deficient; (2) the trial court properly denied Sparre's claim that the cumulative effect of trial counsel's errors entitled him to relief; and (3) Sparre's claims that the postconviction court erred in three other respects were without merit. As to Sparre's habeas petition, the Court held that Sparre was not entitled to relief on his claims of ineffective assistance of appellate counsel. View "Sparre v. State" on Justia Law

by
The Supreme Court affirmed the order of the trial court denying Defendant relief from his conviction and denied Defendant's habeas conviction, holding that Defendant was not entitled to relief. Defendant was found guilty of first-degree felony murder and robbery with a firearm or other deadly weapon. Defendant later moved for postconviction relief. The trial court vacated Defendant's death sentence and ordered a new penalty phase pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016). Defendant appealed the denial of his guilt phase claims and petitioned the Supreme Court for a writ of habeas corpus. In the appeal from the postconviction motion, the Supreme Court affirmed, holding that Defendant was not entitled to relief on his allegations of error. The Court then denied habeas relief, holding that appellate counsel was not ineffective on direct appeal. View "Jordan v. State" on Justia Law

by
The Supreme Court declined to answer a question certified by the Fourth District Court of Appeal regarding whether, under the Fourth Amendment, a warrantless blood draw of an unconscious person incapable of giving consent may be pursuant to Fla. Stat. 316.1932(1)(c) so that the unconscious person can be said to have "consented" to the blood draw, holding that this case fell squarely within the rule announced in Mitchell v. Wisconsin, 139 S. Ct. 2525 (2019). The Wisconsin Supreme Court analyzed the Fourth Amendment issue using the "consent" framework of the statute. During the pendency of this appeal the United States Supreme Court considered a materially indistinguishable issue relating to a similar Wisconsin statute and vacated the Wisconsin Supreme Court's decision. The Supreme Court declined to address the certified question as framed, applied Mitchell, vacated the Fourth District's decision, and remanded, holding that because this case fell within the rule announced in Mitchell, the warrantless blood draw was legal. View "McGraw v. State" on Justia Law

by
The Supreme Court affirmed the order of the circuit court denying John Mack Sketo Calhoun's motion to vacate his conviction of first-degree murder filed under Fla. R. Crim. P. 3.851 and denied Calhoun's petition for a writ of habeas corpus, holding that Calhoun was not entitled to relief. Specifically, the Supreme Court held (1) as to Calhoun's postconviction appeal, the circuit court properly denied relief as to Calhoun's newly discovered evidence claim, trial counsel was not ineffective during the guilt phase, and none of Calhoun's remaining claims warranted relief; and (2) as to Calhoun's habeas petition, Calhoun failed to demonstrate that appellate counsel was ineffective on direct appeal. View "Calhoun v. State" on Justia Law

by
The Supreme Court affirmed the circuit court's summary denial of Appellant's second successive motion for postconviction relief, holding that the petition was both untimely and procedurally barred. Appellant was convicted of first-degree murder and sentenced to death. Several years later, Appellant filed his second successive motion for postconviction relief under Fla. R. Crim. P. 3.851, arguing that, in Buck v. Davis, 137 S. Ct. 759 (2017), the United States Supreme Court established a new fundamental constitutional right that the injection of racial bias and prejudice into a criminal trial constitutes per se ineffective assistance of counsel. Further, Appellant argued that this right applies to convictions and sentences, like his, that became final before Buck. The Supreme Court disagreed, holding (1) Appellant's motion was untimely because Buck did not establish a new right; and (2) because this Court previously addressed the arguments at issue and held that they did not warrant relief Appellant's motion was procedurally barred. View "Bell v. State" on Justia Law

by
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