Justia Florida Supreme Court Opinion Summaries

Petitioner was involved in a single-vehicle car crash in which a single fatality occurred. After a jury trial, Petitioner was found guilty of DUI serious bodily injury and sentenced to five years of incarceration. Petitioner appealed, arguing that the trial court erred by admitting the results of a blood test because the law enforcement officer did not have probable cause to believe Petitioner was under the influence of alcoholic beverages before requiring him to submit to the blood draw taken after the traffic accident, as required by Fla. Stat. 316.1933(1)(a). The Third District Court of Appeal affirmed, ruling that the blood draw was constitutionally permissible under the fellow officer rule and, alternatively, that voluntary consent supported the blood draw. The Supreme Court quashed the decision of the Third District, holding (1) the fellow officer rule was inapplicable because there was no communication between the officers concerning Petitioner; and (2) Petitioner’s consent was involuntary because it was given in response to a threat to suspend his driver license for refusing to give consent by an officer lacking probable cause. View "Montes-Valeton v. State" on Justia Law

After a jury trial, Appellant was found guilty of the kidnapping and murder of Vincent Binder. The jury recommended that Appellant be sentenced to death by a unanimous vote. The trial court agreed with the jury’s unanimous vote and imposed a death sentence. The Supreme Court affirmed, holding (1) the trial court did not err in overruling the State’s use of a peremptory challenge to an African-American juror; (2) excluding people from the jury venire due to their age does not violate the Constitution; (3) the trial court did not err in permitting the State to introduce evidence of other crimes or acts for the purpose of proving a material fact in issue; (4) the cumulative effect of any improper closing comments made by the prosecutor did not entitle Appellant to a new trial; (5) the trial court’s rulings during the penalty phase did not deprive Appellant of a fair trial; (6) Appellant was not entitled to relief under Hurst v. Florida and Hurst v. State; and (7) the death penalty was not disproportionate. View "Truehill v. State" on Justia Law

Here the Supreme Court considered two petitions for writs of prohibition filed in Evans v. State and Rosario v. State. In Evans, the trial court determined that it would death qualify the jury in Evans’ first-degree murder trial and instruct the jury that Evans could receive a death sentence if the jury unanimously made the requisite findings of fact and unanimously recommended a death sentence. In Rosario, the trial court determined that the State was prohibited from seeking the death penalty in a pending prosecution and ordered that the case proceed with a mandatory life maximum penalty. The Fifth District Court of Appeal granted the State’s petition for a writ of prohibition. The Supreme Court denied Evans’ and Rosario’s petitions for writs of prohibition, holding that the trial courts in both cases may proceed with death qualifying juries, as, pursuant to the Court’s holdings in Hurst v. State and Perry v. State, the revised statutory scheme in chapter 2016-13, Laws of Florida, can be applied to pending prosecutions for a jury recommendation of death if twelve jurors unanimously determine that a defendant should be sentenced to death. View "Evans v. State" on Justia Law

In 2015, the Florida Legislature amended the Woman’s Right to Know Act. The amendments constituted the Mandatory Delay Law (the Law), which imposes an additional twenty-four hour waiting period on women seeking to terminate their pregnancies. Petitioners filed a complaint challenging the validity of the Law as a violation of, inter alia, the constitutional privacy rights of Florida women. Petitioners then filed a motion for a temporary injunction grounded on the right of privacy challenge set forth in their complaint. The trial court issued an order granting Petitioners' request for a temporary injunction, finding that the Law infringed Florida women’s fundamental right of privacy. Accordingly, the court applied the strict scrutiny standard of review. The First District Court of Appeal overturned the trial court’s order granting the temporary injunction. The Supreme Court quashed the First District’s decision, holding (1) the trial court properly applied strict scrutiny when reviewing the Law; (2) the First District misapplied and misconstrued Supreme Court precedent by placing the initial evidentiary burden on Petitioners to prove a significant restriction on Florida’s constitutional right of privacy before subjecting the Law to strict scrutiny; and (3) the trial court correctly found that Petitioner established a substantial likelihood of success on the merits. View "Gainesville Woman Care, LLC v. State" on Justia Law

Defendant was convicted and sentenced to death for the first-degree premeditated murder of a corrections officer. The Supreme Court affirmed Defendant’s convictions and sentence. Defendant later filed a motion to vacate his judgment of conviction and sentence pursuant to Fla. R. Crim. P. 3.851, alleging ineffective assistance of counsel and that his execution will violate his constitutional rights. The postconviction court denied relief. Defendant appealed and also filed a petition for writ of habeas corpus, claiming that the jury instructions in capital sentencing are unconstitutional and that trial counsel was ineffective in litigating constitutional challenges to Florida’s capital sentencing statute. The Supreme Court affirmed the postconviction court’s denial of Defendant’s postconviction motion, holding (1) Defendant failed to demonstrate that the postconviction court erred in finding that no Strickland error occurred; (2) Defendant’s claim of possible incompetence at the time of execution was not ripe for review; and (3) Defendant failed to establish that he was entitled to habeas relief. View "Hall v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended death by a vote of ten-to-two. The trial court sentenced Defendant to death. The Supreme Court affirmed on direct appeal. Defendant later filed an amended motion to vacate his conviction and sentence under Fla. R. Crim. P. 3.851. The trial court denied the motion. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of postconviction relief and denied the habeas petition, holding (1) the postconviction court properly denied relief on Defendant’s Rule 3.851 motion; and (2) Defendant was not entitled to habeas relief. View "Bogle v. State" on Justia Law

Defendant was convicted of five counts of first-degree murder, armed robbery, armed kidnapping, and armed burglary with an assault or battery. The jury recommended a sentence of death for each count of first-degree murder by a vote of seven to five. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion by limiting the scope of voir dire; (2) the trial court erred when it failed to conduct a Frye hearing, but the error was harmless; (3) the remaining allegations of error regarding the trial court’s evidentiary rulings failed; (4) the State did not impermissibly shift the burden of proof to Defendant during its guilt phase closing statements; (5) the trial court acted within its discretion to prevent an improper argument proffered by defense counsel during the closing statement of the penalty phase; (6) substantial evidence supported Defendant’s convictions; but (7) Defendant was entitled to a new penalty phase pursuant to Hurst v. State. Remanded. View "Calloway v. State" on Justia Law

After a nonjury trial, Appellant was convicted of first-degree murder, armed robbery, burglary of a dwelling, and grand theft of an automobile. Appellant was sentenced to death for the murder conviction. The Supreme Court affirmed. Thereafter, Appellant filed a motion to vacate his conviction of first-degree murder and sentence of death, presenting twenty-one claims for relief. The postconviction court denied all of Appellant’s claims. Appellant appealed the denial of his postconviction motion and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the postconviction court’s denial of relief and denied habeas relief, holding (1) penalty phase counsel did not provide ineffective assistance; (2) Appellant was not deprived of his right to self-representation; (3) Appellant’s claims that his waivers of guilt phase counsel and both guilt and penalty phase juries were not knowing, intelligent, and voluntary were procedurally barred; and (4) as to Appellant’s habeas claims, his arguments regarding the effective assistance of appellate counsel were without merit. View "Knight v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder. The jury recommended death sentences for the murder convictions, and the trial court sentenced Defendant to death. The Supreme Court affirmed the convictions but vacated Defendant’s death sentences, holding (1) the trial court did not err by denying Defendant’s motion to suppress his confession and the corresponding video recording of it; (2) the trial court did not abuse its discretion by precluding a false confession expert from testifying that Defendant’s statement to law enforcement was coerced; (3) the trial court did not err by advising the jury that the ultimate decision to impose the death penalty rested with the court; (4) the evidence was sufficient to support the first-degree murder convictions; but (5) the term-of-years sentences imposed against Defendant’s codefendants precluded Defendant’s death sentences. View "McCloud v. State" on Justia Law

After a jury trial, Appellant was convicted of three counts of first-degree murder, one count of attempted first-degree murder, one count of armed robbery, and one count of first-degree arson. The trial court imposed two sentences of death. Defendant appealed his convictions and sentences. The Supreme Court affirmed the trial court’s judgments of conviction and sentences of death, holding (1) the trial court properly admitted the statements of one victim as a dying declaration; (2) the trial court did not err in admitted certain out-of-court and in-court identifications of Appellant; (3) the trial court did not err in admitting nearly four dozen autopsy and hospital photographs of the murder victims; (4) the trial court properly found that Appellant committed the murder of one victim in order to avoid arrest; (5) competent, substantial evidence of guilt supported Appellant’s convictions; and (6) Appellant’s death sentences satisfied the Court’s proportionality requirement. View "Davis v. State" on Justia Law