Justia Florida Supreme Court Opinion Summaries

Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant’s conviction and sentence, holding (1) the trial court properly considered in mitigation Defendant’s IQ score in conjunction with evidence of his low cognitive functioning; (2) Defendant was not entitled to relief on his claim that the trial court failed to consider, find, and weigh as a mitigating circumstance that Defendant had a history of drug and alcohol abuse; (3) trial court did not err in finding as aggravating circumstances that the homicide was committed in a cold, calculated, and premeditated manner and was especially heinous, atrocious, or cruel; (4) Defendant’s claim that Florida’s death penalty scheme is unconstitutional under Ring v. Arizona was without merit; (5) there was sufficient evidence to affirm Defendant’s conviction for first-degree murder; and (6) Defendant’s death sentence was proportional to other cases where the Court has upheld a sentence of death. View "Martin v. State" on Justia Law

Petitioner was convicted of four counts of armed sexual battery and ultimately sentenced to four life sentences as upward departure sentences. The second district affirmed Petitioner’s four life sentences. Petitioner later filed a motion to correct illegal sentence under Fla. R. Crim. P. 3.800(a), claiming that under Apprendi v. New Jersey and Blakely v. Washington he was entitled to a jury trial at his resentencing to determine the factual basis for the upward departure. The circuit court denied the motion, finding that Petitioner’s sentences were within their statutory maximums. The Second District affirmed, concluding that Petitioner’s claim of Apprendi error was not a ground for relief under rule 3.800(a) because it was not preserved and raised on direct appeal. The Supreme Court quashed the Second District’s decision and remanded to the district court for the application of a harmless error analysis, holding that Petitioner’s four life sentences were unconstitutionally enhanced under Apprendi and Blakely, and therefore, the sentences were illegal under rule 3.800(a). View "Plott v. State" on Justia Law

After a jury trial, Appellant was convicted of the kidnapping, capital sexual battery, and first-degree murder of an eleven-year-old girl. The trial court sentenced Appellant to death for the murder. The Supreme Court affirmed Appellant’s convictions and sentences on appeal. Appellant subsequently filed a motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, presenting several claims. The postconviction court summarily denied all claims. The Supreme Court affirmed, holding (1) Appellant’s argument that criminal defense counsel should have unlimited authority to conduct interviews to probe jurors for possible misconduct was without merit; (2) the postconviction court properly denied Appellant’s claims that the trial court improperly instructed the jury regarding its role; (3) the postconviction court did not err when it held that Florida’s capital sentencing statute is not unconstitutional; and (4) Appellant’s challenge to the constitutionality of Florida’s lethal injection procedures was without merit. View "Smith v. State" on Justia Law

In Sirota v. State, the court of appeal certified a question to the Supreme Court regarding the scope and proper application of the Court’s decision in Morgan v. State. Thereafter, the Supreme Court decided Alcorn v. State, wherein the Court receded from Morgan with respect to the standard for establishing prejudice as to ineffective assistance of counsel claims in which the defendant rejected a plea offer based on misadvice. After Alcorn became final, the Court issued an order directing the defendant below to show cause why the Court should not summarily quash the court of appeal’s decision in Sirota and remand for reconsideration in light of Alcorn. After the parties responded, the Supreme Court quashed the court of appeal’s decision in Sirota and remanded for further proceedings consistent with the Court’s decision in Alcorn. View "State v. Sirota" on Justia Law

Appellant was convicted and sentenced to death for the first-degree murder of Monquell Wimberly. Appellant was also convicted of the first-degree felony murder of Patrick Stafford, for which Stafford was sentenced to life imprisonment. The Supreme Court affirmed Appellant’s convictions and sentence of death, holding (1) there was no fundamental error in the admission of a videotaped statement Appellant gave to detectives after he was taken into custody; (2) there was no prejudicial error in the admission of a codefendant’s out-of-court statement; (3) the admission of testimony concerning an eyewitness’s fear of the shoot did not constitute fundamental error; (4) Appellant was not entitled to relief on his claim of juror misconduct or premature deliberation; and (5) competent, substantial evidence supported the verdict of guilt as to the first-degree murder conviction and the felony murder conviction. View "Sheppard v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder and one count of armed carjacking. The trial court sentenced Appellant to death. The Supreme Court affirmed Appellant’s convictions and sentences on appeal. Appellant subsequently filed a motion for postconviction relief, raising twenty-eight claims. After an evidentiary hearing on several of those claims, the circuit court denied relief. Appellant appealed, raising twenty-one claims, and also filed a habeas petition raising two claims of ineffective assistance of appellate counsel. The Supreme Court (1) affirmed the postconviction court’s order denying relief on all postconviction claims, holding that Appellant failed to establish that any errors occurred which, either individually or cumulatively, would entitle him to a new trial; and (2) denied relief on both claims Appellant raised in his petition for writ of habeas corpus, as both claims were procedurally barred. View "Deparvine v. State" on Justia Law

Appellant was convicted of first-degree murder in the shooting death of a law enforcement officer, which occurred after the officer stopped Appellant for a traffic infraction. The jury recommended that the death penalty be imposed, and the circuit court sentenced Appellant to death. Appellant filed an amended motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, alleging that his trial counsel provided ineffective assistance. The court below denied the motion in a final order. The Supreme Court affirmed, holding that Appellant failed to satisfy the Washington v. Strickland standard in the postconviction proceeding held below. View "Bailey v. State" on Justia Law

Appellant was convicted of first-degree murder and sentenced to death for killing a Florida Highway Patrol Trooper. The Governor set a death warrant for Appellant and scheduled his execution for February 26, 2014. This appeal concerned the denial of Appellant’s amended third successive motion for postconviction relief in which he challenged the Florida lethal injection protocol as applied to him. The Supreme Court affirmed the postconviction court’s denial of relief, holding (1) Appellant's suggestion that the Court depart from its established precedent as to the proper standard to apply to an Eighth Amendment challenge to the lethal injection protocol was unavailing; (2) the use of midazolam hydrochloride in the 2013 lethal injection protocol does not violate the Eighth Amendment; (3) the forced administration of vecuronium bromide does not violate Appellant’s Fourteenth Amendment rights under Sell v. United States because the holding of Sell does not apply to these circumstances; and (4) the postconviction court did not err in denying Appellant’s request to strike a witness’s testimony.View "Howell v. State " on Justia Law

After a jury trial, Appellant was convicted of the first-degree murder, kidnapping, and sexual battery of a nine-year-old and sentenced to death. After the Governor signed the warrant in this case Appellant filed numerous public records requests, a second successive motion for postconviction relief, and a request for a stay of execution. The circuit court denied Appellant's public records requests, his postconviction petition, and his request for a stay of execution. The Supreme Court affirmed in all respects, holding that the circuit court did not err in its rulings. View "Chavez v. State" on Justia Law

After a second jury trial, Appellant was convicted of first-degree murder and robbery and was sentenced to death. The Supreme Court affirmed the convictions but twice remanded for new penalty phases. Each time, the trial court sentenced Defendant to death. The Supreme Court affirmed the sentence of death. Appellant subsequently moved to vacate judgment of convictions and sentences, alleging ineffective assistance of counsel. The postconviction court denied all claims presented in Appellant’s motion to vacate. The Supreme Court affirmed, holding that the postconviction court did not err in denying Appellant’s claims of ineffective assistance of counsel during his second guilt phase trial and during his fourth penalty phase trial.View "Lebron v. State" on Justia Law