Justia Florida Supreme Court Opinion Summaries

Defendant was fifteen years old when she took part in an attempted robbery that resulted in a death. Defendant was convicted of first-degree murder, among other crimes. The trial court imposed a mandatory sentence of life imprisonment without the possibility of parole for the murder. A decade after Defendant’s convictions and sentences became final, the U.S. Supreme Court issued its decision in Miller v. Alabama. Defendant subsequently filed a motion for postconviction relief and to correct an illegal sentence, asserting that her sentence was unconstitutional under Miller and, therefore, she was entitled to be resentenced. The trial court denied the motion on the basis of the First District Court of Appeal’s precedent in Gonzales v. State, which held that Miller did not apply retroactively. The First District affirmed. The Supreme Court reversed, holding (1) the Supreme Court’s decision in Miller applies retroactively to juvenile offenders whose convictions and sentences were final at the time Miller was decided; and (2) based on the Court’s decision in Horsley v. State, the appropriate remedy for any juvenile offender whose sentence is now unconstitutional under Miller is to conduct a resentencing proceeding consistent with the provisions of chapter 2014-220, Laws of Florida. View "Falcon v. State" on Justia Law

Defendant was seventeen years old when he participated in the robbery of a convenience store, during which an owner was killed. The jury convicted Defendant of first-degree murder, among other charges. Defendant was sentenced to life imprisonment without the possibility of parole for the murder. While Defendant’s appeal was pending, the U.S. Supreme Court decided Miller v. Alabama. Defendant subsequently filed a motion to correct his sentence, asserting that he was entitled to be resentenced with individualized consideration based on Miller. The trial court agreed with Defendant but concluded that it did not have the discretion to consider a term of years as a sentencing option. Thereafter, the court again sentenced Defendant to life imprisonment without the possibility of parole. The Fifth District Court of Appeal vacated Defendant’s sentence, concluding that the only sentence now available in Florida for a charge of capital murder committed by a juvenile was life with the possibility of parole after twenty-five years. The Supreme Court quashed the underlying decision and remanded the case for resentencing, holding that the proper remedy is to apply chapter 2014-220, Laws of Florida, to all juvenile offenders whose sentences are unconstitutional under Miller. View "Horsley v. State" on Justia Law

When he was seventeen years old, Defendant was tried as an adult and convicted of, among other nonhomicide offenses, three counts of sexual battery while possessing a weapon, two counts of robbery, and one count of kidnapping. After Defendant was initially sentenced to life imprisonment plus sixty years, in light of the recently issued Graham v. Florida decision, the trial court resentenced Defendant to concurrent thirty-year sentences for the sexual batteries. The remaining sentences were to run consecutively. The Fifth District Court of Appeal affirmed, holding that Graham does not apply to term-of-years prison sentences because such sentences do not constitute life imprisonment. The Supreme Court quashed the decision below and remanded for resentencing, holding (1) the constitutional prohibition against cruel and unusual punishment under Graham is implicated when a juvenile nonhomicide offender’s sentence does not afford any meaningful opportunity to obtain release based on demonstrated maturity and reform; and (2) because Defendant’s aggregate sentence did not afford him this opportunity, his sentence was unconstitutional under Graham. View "Henry v. State" on Justia Law

When Defendant was fourteen years old he pleaded guilty to attempted first-degree murder, attempted armed robbery, and aggravated battery. The trial court adjudicated Defendant guilty as charged and imposed prison terms of seventy years for the attempted murder conviction and twenty-five years for the attempted armed robbery conviction. Defendant appealed and filed a motion pursuant to Fla. R. Crim. P. 3.800(b)(2), arguing that, under the rationale of Graham v. Florida, his seventy-year prison sentence constituted cruel and unusual punishment. The trial court denied the requested relief. The First District Court of Appeal affirmed, holding that Graham did not apply in Defendant’s case because he did not face a life sentence without the possibility of parole. The Supreme Court quashed the First District’s decision to the extent it affirmed the seventy-year prison sentence and remanded to Defendant’s sentencing court, holding that Defendant’s seventy-year prison sentence did not provide a meaningful opportunity for future release, and therefore, the sentence was unconstitutional in light of Graham. View "Gridine v. State" on Justia Law

Defendant was convicted of the first-degree murder of his father and sentenced to death. The Supreme Court affirmed the conviction and sentence, holding (1) the evidence supported the finding that the murder was committed in a cold, calculated, and premeditated manner and that the murder was motivated by financial gain; (2) the trial court erred in finding that the murder was especially heinous, atrocious, or cruel, but the error was harmless; (3) because Ring v. Arizona did not apply in this case, Defendant’s argument that Florida’s sentencing scheme is unconstitutional under Ring was denied; (4) the death sentence in this case was proportionate; and (5) the jury had competent, substantial evidence on which to find Defendant guilty of first-degree murder. View "Campbell v. State" on Justia Law

Defendant was convicted of first-degree murder, attempted first-degree murder, burglary of a dwelling with a battery therein, and attempted robbery with a deadly weapon. Defendant was sentenced to death for the murder. The Supreme Court affirmed Defendant’s convictions and sentences on appeal. Defendant later filed a motion to vacate judgment of convictions and sentences, alleging several claims of error. The postconviction court denied all claims. Defendant appealed the denial of his postconviction motion and also filed a petition for writ of habeas corpus, presenting two habeas claims. The Supreme Court affirmed the postconviction court’s order denying postconviction relief on all claims and denied habeas relief, holding that the postconviction court did not err in its judgment and that Defendant’s habeas claims were without merit. View "Miller v. State" on Justia Law

After a jury trial, Emilia Carr was found guilty of first-degree murder and kidnapping. The trial court sentenced Carr to death, concluding that the aggravating circumstances outweighed the mitigating circumstances. The Supreme Court affirmed Carr’s conviction for first-degree murder and her sentence of death, holding (1) the trial court’s evidentiary rulings as to the admissibility of certain documents were proper; (2) the trial court did not err by denying Carr’s motions to continue; (3) the trial court did not err by overruling Carr’s objections to certain prosecutorial comments during the penalty phase; (4) the trial court did not err in its treatment of the mitigating evidence; (5) the trial court did not err in finding the cold, calculated, and premeditated aggravator and the heinous, atrocious, or cruel aggravator; (6) the death sentence was proportionate; and (7) there was sufficient evidence to support Carr’s first-degree murder conviction. View "Carr v. State" on Justia Law

In this “Craigslist killer case,” Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not violate the Supreme Court’s holding in Muhammad v. State by not calling its own witnesses that had knowledge of mitigation after Defendant decided to waive the presentation of mitigating circumstances; (2) Defendant failed to provide a good-faith basis for suggesting that the Court recede from controlling precedent established in Hamblen v. State, which subjects a trial court’s judgment about whether to call its own mitigation witnesses or appoint special mitigation counsel to an abuse of discretion standard of review; (3) the trial court did not violate Ring v. Arizona in sentencing Defendant to death; (4) there was sufficient evidence to support the conviction; and (5) Defendant’s death sentence was proportionate. View "Sparre v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder and burglary of a dwelling with a firearm. The trial court sentenced Defendant to death for the two murders. The Supreme Court affirmed Defendant’s convictions and death sentences, holding (1) the trial court did not commit error in its evidentiary rulings; (2) no fundamental error occurred in the trial court’s placement of certain restrictions on Defendant’s presentation of his case; (3) the prosecutor did not improperly comment on Defendant’s guilt in front of the jury; (4) the trial court did not err in finding certain aggravating circumstances; (5) there was sufficient evidence to support the convictions; (6) the death sentences were proportionate; and (7) the trial court did not violate the attorney-client privilege by appointing Defendant’s standby counsel and investigators to present mitigation. The Court also prospectively modified the principles and procedures articulated in Muhammad v. State to the limited extent that trial courts should utilize an independent, special counsel, rather than standby counsel, to present mitigation evidence even when the defendant waives mitigation - as was done in this case. View "Marquardt v. State" on Justia Law

After a jury trial, Appellant was convicted of the murder of a seventy-year-old woman. Appellant was sentenced to death. The Supreme Court affirmed on appeal. Appellant subsequently filed a motion to vacate his conviction and sentence pursuant to Fla. R. Crim. P. 3.851, asserting, inter alia, that he received ineffective assistance of trial counsel. The postconviction court denied all claims. Appellant appealed the denial of his postconviction motion and also petitioned for a writ of habeas corpus. The Supreme Court affirmed the denial of Appellant’s postconviction claims and denied his petition for a writ of habeas corpus, holding (1) the postconviction court did not err in determining that Appellant failed to demonstrate prejudice by any purported failure to trial counsel; and (2) the majority of Appellant’s claims were not cognizable in a petition for habeas relief, and the remainder of his claims were without merit. View "Zommer v. State" on Justia Law