Justia Florida Supreme Court Opinion Summaries

Appellant was found guilty of first-degree murder and three counts of sexual battery with the use of a deadly weapon or physical force, among other crimes. Appellant was sentenced to death. Appellant later filed a motion for postconviction relief pursuant to Fla. R. Crim. P. 3.850 and 3.851, alleging a claim of newly discovered evidence. Specifically, Appellant alleged that he was not the shooter and that his codefendant was the shooter. The trial court denied relief, determining that the newly discovered evidence was not credible and would not have changed the outcome of the trial. The Supreme Court affirmed. Appellant then filed a successive postconviction motion pursuant to rule 3.851, asserting claims of newly discovered evidence and ineffective assistance of postconviction counsel. The trial court summarily denied the motion. The Supreme Court affirmed, holding (1) the record conclusively showed that Appellant was not entitled to relief on his claim of newly discovered evidence; and (2) Appellant’s ineffective assistance of postconviction counsel claim was not cognizable in a rule 3.851 motion. View "Kormondy v. State" on Justia Law

Appellant was convicted of two counts of first-degree murder, two counts of kinapping, and two counts of robbery. The trial court imposed two sentences of death for each murder. The Supreme Court affirmed on appeal. Appellant later filed a motion for postconviction relief, raising twelve issues. After an evidentiary hearing conducted on two of Appellant’s claims, the postconviction court denied relief. The Supreme Court affirmed, holding that the postconviction court did not err in denying Appellant’s claims that trial counsel was ineffective during the guilt phase, during the penalty phase, and during jury selection. View "Wade v. State" on Justia Law

After a jury trial, Norman McKenzie was convicted of two counts of first-degree murder. The trial court sentenced McKenzie to death for the murders. The Supreme Court affirmed the convictions and sentences. McKenzie later filed a motion to vacate the convictions and sentences pursuant to Fla. R. Crim. P. 3.851, asserting four claims. The postconviction court summarily denied the motion without an evidentiary hearing. McKenzie appealed and also petitioned for a writ of habeas corpus. The Supreme Court affirmed, holding (1) McKenzie’s ineffective assistance of counsel claim, in which he presented several issues arising from his decision to represent himself during his capital criminal proceeding, was properly denied; (2) McKenzie was not entitled to a second proportionality review at the postconviction appellate stage for evidence he chose not to present during his capital trial; and (3) McKenzie was not entitled to relief on his claim that because he was mentally ill, to execute him would be unconstitutional. View "McKenzie v. State" on Justia Law

Appellant was convicted of first-degree murder, attempted armed robbery, and grand theft of a motor vehicle. The trial court imposed a sentence of death for the murder conviction. The Supreme Court affirmed on appeal. Appellant later filed a motion for postconviction relief, alleging twelve claims. After an evidentiary hearing, the postconviction court denied Appellant’s motion to the extent that it requested a new guilt phase but granted the motion to the extent that it requested a new penalty phase. Appellant appealed and filed a petition for a writ of habeas corpus. The Supreme Court affirmed the postconviction court’s order and denied Appellant’s habeas petition, holding (1) the postconviction court did not err in denying Appellant’s request for a new guilt phase trial; and (2) Appellant failed to establish that he was entitled to habeas corpus relief. View "Blake v. State" on Justia Law

Appellant pleaded no contest to two counts of first-degree murder and one count of sexual battery on a child under the age of twelve. After a capital penalty-phase trial, the trial court sentenced Appellant to death for the murder of his stepdaughter. The Governor signed the death warrant on September 22, 2014. Appellant subsequently filed a second successive motion for postconviction relief, presenting three claims. The trial court denied the motion. The Supreme Court affirmed, holding (1) Appellant was not entitled to relief on his claim that postconviction counsel rendered ineffective assistance; (2) Appellant’s claim that Florida’s lethal injection protocol violates the prohibition against cruel and unusual punishment did not warrant reconsideration of the Court’s prior decisions upholding the constitutionality of the current protocol; and (3) the trial court did not abuse its discretion in sustaining objections made by various agencies to Appellant’s public records requests. View "Banks v. State" on Justia Law

At issue in this case was whether the use of real time cell site location information to track a defendant violates the Fourth Amendment if probable cause was not provided to access and use that information. Defendant moved to suppress the evidence derived from the real time cell site information obtained from his cell phone for lack of probable cause. The trial court denied the motion, concluding that the application for the order obtained by officers authorizing them to obtain the information did not contain a sufficient factual basis on which to issue a search warrant but that a warrant was not required to use Defendant’s real time cell site location data to track him on public streets where he had “no expectation of privacy.” The Fourth District affirmed. The Supreme Court quashed the decision of the Fourth District, holding (1) Defendant had a reasonable expectation of privacy in the location signals transmitted solely to enable the private and personal use of his cell phone, even on public roads, and therefore, probable cause was required; and (2) probable cause did not support the search in this case, and the evidence obtained as a result of this search was subject to suppression. Remanded. View "Tracey v. State" on Justia Law

Defendant was charged with several offenses, but the trial court entered an order declaring Defendant incompetent to proceed to trial. The trial court later held a competency hearing, during which defense counsel stipulated that Defendant was competent to proceed. The court did not enter a written order determining that Defendant was competent to proceed to trial, but the matter nevertheless proceeded to a jury trial. Defendant was found guilty of two charges. On appeal, Defendant argued that the lack of a written order adjudicating him competent required reversal of his conviction and a new trial. The Fifth District Court of Appeal affirmed, concluding that the lack of a written order could be cured without a new trial because the trial court found Defendant competent based upon the stipulation of defense counsel. The Supreme Court quashed the judgment of the Fifth District in part, holding (1) Defendant’s stipulation as to his own competency did not absolve the trial court from its duty to independently make a determination of Defendant’s competency to proceed; and (2) the remedy for such a violation depends upon the circumstances of each case. View "Dougherty v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, kidnapping, and sexual battery. Defendant was sentenced to death for the murder conviction. On appeal, Defendant challenged only the propriety of the death sentence. The Supreme Court affirmed the convictions and sentence of death, holding (1) the evidence was sufficient to support the convictions; (2) the trial court did not fail to remain neutral during the penalty-phase proceedings; (3) the trial court’s findings on aggravators and mitigators were not in error with the exception of its finding of an avoid arrest aggravator, which error was harmless beyond a reasonable doubt; (4) Defendant was not entitled to relief on his claim that his death sentence was unconstitutional based on Ring v. Arizona; and (5) the death sentence in this case was a proportionate penalty. View "Davis v. State" on Justia Law

Appellant was convicted of murder and sentenced to death. The trial court subsequently ordered a new trial, after which Appellant was again convicted of murder and sentenced to death. Appellant later filed a postconviction motion. The postconviction court ultimately denied Appellant’s postconviction motion. Appellant appealed the denial of his postconviction motion and filed a petition for a writ of habeas corpus. The Supreme Court affirmed the postconviction court’s denial of Appellant’s claims and denied habeas corpus relief, holding (1) the postconviction court properly found that Appellant was competent to proceed with his postconviction proceedings, correctly denied Appellant’s prosecutorial misconduct claim, and properly denied Appellant’s claim of a Brady violation; and (2) Appellant was not entitled to habeas relief based on his claims of ineffective assistance of appellate counsel. View "Huggins v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant’s convictions and sentences on appeal. Defendant later filed a motion for postconviction relief, raising twenty-nine claims. The circuit court denied each of Defendant’s claims. Defendant appealed the denial of five claims and filed a petition for a writ of habeas corpus, raising two additional claims. The Supreme Court affirmed the postconviction court’s denial of Defendant’s claims and denied Defendant’s petition for a writ of habeas corpus, holding (1) the postconviction court properly denied Defendant’s claims of Brady violations, ineffective assistance of trial counsel, improper juror communication, and cumulative error; and (2) Appellant was not entitled to habeas relief based on alleged ineffective assistance of appellate counsel. View "Whitton v. State" on Justia Law