Justia Florida Supreme Court Opinion Summaries

Defendant was indicted on two counts of first-degree murder. Defendant moved to suppress any statements he made to law enforcement and any evidence obtained as a result of those statements, asserting that he was in custody when he was questioned and was not read the Miranda warnings and that he was improperly denied access to his attorney. The trial court denied the motion to suppress. The Second District Court of Appeal reversed, holding (1) Defendant was not in custody when he initially confessed to the murders, but (2) once Defendant confessed and was read the Miranda warnings, he was in custody and should have been informed that the attorney retained on his behalf was at the sheriff’s office where Defendant was being interrogated and was available to speak to Defendant. The Supreme Court quashed the Second District’s decision and remanded, holding (1) when a person is questioned in a non-public location and an attorney retained on his behalf appears at the location, due process requires that law enforcement notify the person with regard to the presence and purpose of the attorney, regardless of whether the person is in custody; and (2) the Miranda violation in this case constituted harmful error. View "State v. McAdams" on Justia Law

Curtis Lee requested public records from the Board of Trustees, Jacksonville Police & Fire Pension Fund (Pension Fund), which imposed certain conditions before allowing Lee to inspect and photocopy the records. Lee sought declaratory relief alleging that the conditions and fees were not legally valid. The trial court determined that two conditions were imposed in violation of Fla. Stat. 119.07. The First District Court of Appeal affirmed. Lee then moved for attorney’s fees under Fla. Stat. 119.12. The trial court denied the request. The First District reversed, concluding that the lower court erred in determining that Lee was not entitled to attorney’s fees because the Public Fund’s violation was neither knowing, willful, nor done with malicious intent. The Supreme Court approved the decision, holding (1) a prevailing party is entitled to statutory attorney’s fees under the Public Records Act when the trial court finds that the public agency violated a provision of the Act in failing to permit a public record to be inspected or copied; and (2) there is no additional requirement that a trial court find that the public agency did not act in good faith, acted in bad faith, or acted unreasonably before awarding attorney’s fees. View "Bd. of Trs., Jacksonville Police & Fire Pension Fund v. Lee" on Justia Law

June Dhar was a short-term renter of an automobile that was detected by an automated traffic camera running a red light. The vehicle was registered to Dollar Rent A Car Systems, Inc. Dollar was sent a notice of violation. Dollar responded by sending an affidavit identifying Dhar as the person having control of the vehicle at the time of the violation. Thereafter, Dhar was issued a uniform traffic citation. Dhar filed a motion to dismiss, arguing that as a short-term renter of the motor vehicle she was treated unequally because she was not initially issued a notice of citation under Fla. Stat. 316.0083(1)(b)1.a and therefore could not avoid the payment of added court costs by paying the statutory penalty of $158. The trial court granted Dhar’s motion, concluding that the unequal treatment of short-term renters violated equal protection. The court of appeal affirmed the lower court’s order granting Dhar’s motion to dismiss. The Supreme Court affirmed, holding that Fla. Stat. 316.0083 is unconstitutional as applied to short-term vehicle renters such as Dhar. View "City of Fort Lauderdale v. Dhar" on Justia Law

Defendant was convicted of both sexual battery on a person under twelve years of age and lewd or lascivious molestation on a person under twelve years of age for a single act. Defendant appealed, arguing that his dual convictions violated his constitutional protection against double jeopardy. The court of appeal concluded that convictions for both lewd or lascivious molestation and sexual battery arising from the same act do not violate the constitutional prohibition against double jeopardy. The Supreme Court affirmed, holding that Defendant’s separate sentences for capital sexual battery and lewd or lascivious molestation arising from a single act do not violate the prohibition against double jeopardy. View "Roughton v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder, attempted first-degree murder, and related crimes. The trial court sentenced Defendant to death. The Supreme Court affirmed the conviction and death sentence. Appellant later filed a motion for postconviction relief, which the trial judge denied. Appellant appealed and also petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court remanded for a new penalty phase and denied Appellant’s habeas petition, holding (1) trial counsel was ineffective for failing to investigate and present mitigation, including Appellant’s background and intellectual functioning, at the penalty phase; and (2) Appellant’s claims in his habeas petition were unavailing. View "Salazar v. State" on Justia Law

Appellant was found guilty of the first-degree murder and aggravated child abuse of her three-year-old son, Lazaro. The Supreme Court vacated Appellant’s convictions and remanded for a new trial, holding that the pervasiveness and the cumulative effect of the prosecutor’s multiple improper closing arguments in the guilt phase, which repeatedly invoked “justice for Lazaro” and appealed to the passions of the jury, constituted impermissible prosecutorial misconduct and deprived Appellant of a fair trial. Moreover, most of the improper comments were objected to, and those objections were overruled by the trial court, increasing the prejudicial effect of the comments. View "Cardona v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder. Defendant was sentenced to death. The Supreme Court affirmed. Defendant subsequently filed a motion for postconviction relief, alleging ineffective assistance of trial counsel, due process violations, and a claim under Ring v. Arizona. The trial court denied postconviction relief. Defendant appealed the denial of relief and also filed a petition for a writ of habeas corpus and for extraordinary relief. The Supreme Court reversed the trial court’s denial of postconviction relief, holding that Defendant’s counsel provided ineffective assistance to the prejudice of Defendant. Remanded for a new trial. View "Ibar v. State" on Justia Law

Appellant was indicted on charges of two counts of first-degree premeditated murder. Appellant entered written and oral guilty pleas to all charges. Appellant subsequently waived his right to a penalty phase jury and his right to be present in the penalty phase. Appellant was sentenced to death for the murders. The Supreme Court affirmed the trial court’s judgment. Appellant later filed a motion for postconviction relief, alleging ineffective assistance of counsel, among other claims. The circuit judge denied all claims. The Supreme Court affirmed, thus denying Appellant’s claims that trial counsel provided constitutionally ineffective assistance and Appellant’s challenges to the constitutionality of several of Florida’s death penalty provisions. View "Allred v. State" on Justia Law

Lucious Boyd was convicted of first-degree murder and sentenced to death. Boyd filed a motion to vacate his conviction and sentence. The circuit court denied relief. Boyd appealed the circuit court’s order denying postconviction relief and also petitioned for a writ of habeas corpus. As to Boyd’s postconviction relief claims, the Supreme Court held (1) Boyd failed to show that he was entitled to a new trial on his claims of actual juror bias; and (2) Boyd was not entitled to relief on his ineffective assistance of counsel claims. The Court also denied Boyd’s petition for writ of habeas corpus. View "Boyd v. State" on Justia Law

Defendant was arrested after law enforcement officers discovered marijuana plants growing in Defendant’s home. The officers did not make any efforts to obtain a search warrant before entering the home. Defendant filed a motion to suppress. The circuit denied denied the motion to suppress, concluding that the inevitable discovery doctrine applied in this case. Defendant subsequently entered a guilty plea and reserved the right to appeal the suppression issue. The Court of Appeal affirmed, finding that the trial court properly applied the inevitable discovery doctrine. The Supreme Court reversed, holding that, under the totality of the evidence, the lower courts improperly applied the inevitable discovery doctrine, and the trial court should have suppressed the evidence obtained from the illegal search. View "Rodriguez v. State" on Justia Law