Justia Florida Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of first-degree murder, attempted first-degree murder, grand theft of a motor vehicle, home invasion robbery, and aggravated assault on a police officer. The trial court imposed a sentence of death for the murder conviction. The Supreme Court affirmed the convictions and sentences. Appellant subsequently filed a motion to vacate his conviction and sentence of death pursuant to Fla. R. Crim. P. 3.851, presenting ten claims. The postconviction court summarily denied all claims except Appellant’s claim of ineffective assistance of counsel. After an evidentiary hearing, the postconviction court denied Appellant’s ineffective assistance of counsel claim. The Supreme Court affirmed the trial court’s order denying postconviction relief, holding (1) Appellant’s trial counsel were not ineffective; and (2) Appellant’s challenges to the death penalty in Florida were either waived, procedurally barred, meritless, or premature. View "Turner v. State" on Justia Law

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

Plaintiff filed a lawsuit against Defendant, her former employer, alleging that Defendant took adverse employment actions against her after she revealed that she was pregnant. The trial court dismissed Plaintiff’s lawsuit for failure to state a cause of action. The court of appeal affirmed, concluding that Florida law does not prohibit pregnancy discrimination in employment practices. The Supreme Court quashed the court of appeal’s decision and remanded with directions that the trial court reinstate Plaintiff’s complaint, holding that the provision in the Florida Civil Rights Act (FCRA) making it an unlawful employment practice for an employer to discriminate based on an individual’s sex includes discrimination based on pregnancy, which is “a natural condition and primary characteristic unique to the female sex.” View "Delva v. Continental Group, Inc. " on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder. Appellant was sentenced to death for the murders. The Supreme Court affirmed the convictions and sentences. Appellant subsequently 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 Appellant’s motion without an evidentiary hearing. Appellant appealed the summary denial of his motion and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of the Rule 3.851 motion and denied the petition for writ of habeas corpus, holding, among other things, that (1) Appellant was afforded constitutionally effective assistance of trial counsel; (2) Appellant’s allegation of improper argument by the prosecution was procedurally barred; and (3) Appellant’s claim that to execute him would be unconstitutional because he was mentally ill was without merit. View "McKenzie v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Appellant’s convictions of first-degree murder and his sentences of death on appeal. Appellant subsequently filed a motion to vacate judgment of conviction and death sentence. After an evidentiary hearing, the circuit court denied the motion. The Supreme Court affirmed the circuit court’s denial of Appellant’s postconviction motion and denied habeas relief, holding (1) trial counsel did not render constitutionally deficient assistance by failing to object to the striking of a minority venireperson, failing to object to certain comments made by the trial court and the State, failing to file a motion to preclude the State from seeking the death penalty, and failing to investigate and present certain mitigation evidence; (2) Florida’s method of execution by lethal injection did not violate Appellant’s constitutional rights; and (3) appellate counsel was not ineffective for failing to raise on appeal the unconstitutionality of the strike of the minority venireperson. View "Frances v. State" on Justia Law

After a jury trial, Defendant was convicted of sexual battery for penetrating the victim’s vagina with his penis and lewd or lascivious molestation for intentionally touching the victim’s breasts, genitals, genital area, buttocks, or the clothing covering them. On appeal, the Second District Court of Appeal reversed and remanded for the trial court to vacate Defendant’s conviction for lewd or lascivious molestation, concluding that double jeopardy prohibited convictions for both sexual battery and lewd or lascivious molestation in a single criminal episode. The Supreme Court quashed the decision of the Second District and remanded to the district court for an order affirming Defendant’s convictions, holding that Defendant’s convictions involved offenses of a separate character and type, which were distinct criminal acts that do no violate double jeopardy. View "State v. Drawdy" on Justia Law

In 1995, Petitioner was convicted of first-degree felony murder, aggravated child abuse, and sexual battery. The jury recommended the death penalty, and the trial court imposed the death penalty. The Supreme Court affirmed on appeal. In 2006, Petitioner filed a third amended motion to vacate the judgments of convictions and sentences, asserting fourteen claims of error. After an evidentiary hearing, the postconviction court denied Petitioner’s motion for postconviction relief. The Supreme Court affirmed the postconviction court’s denial of Petitioner’s motion for postconviction relief and denied his petition for a writ of habeas corpus, holding (1) Petitioner failed to establish that the State violated Brady v. Maryland and Giglio v. United States; and (2) Petitioner’s trial counsel did not provide ineffective assistance. View "Davis v. State" on Justia Law

After a jury trial, Defendant was convicted of three counts of sexual battery and one count each of kidnapping, aggravated battery, and attempted robbery. Defendant was sentenced to life imprisonment for each sexual battery count and the kidnapping count. Defendant appealed, arguing that the trial court abused its discretion in refusing to give a curative instruction relating to statements the prosecutor made during voir dire. The Second District Court of Appeals found that the prosecutor’s remarks were improper but that there was “no reasonable possibility that the failure to give a curative instruction affected the verdict.” The Supreme Court quashed the Second District’s decision, holding that the prosecutor impermissibly commended during voir dire on Defendant’s constitutional right to remain silent, and the comments were not harmless beyond a reasonable doubt. View "Marston v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder, armed robbery with a deadly weapon, and arson. Appellant was sentenced to death for the murders. Appellant’s death warrant was signed and his execution set for March 20, 2014. Appellant filed several post-trial motions, all of which were denied. In this appeal, Appellant challenged the denial of his second successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, his motion to declare Fla. Stat. 922.052 unconstitutional, and his motion to dismiss his death warrant. The Supreme Court affirmed the postconviction court’s denial of relief on all three motions and denied Appellant’s motion for a stay of execution, holding that the postconviction court did not err in its judgment. View "Henry v. State" on Justia Law

Michelle McCall received prenatal medical care at a United States Air Force clinic as an Air Force dependent. McCall died after delivering her son as a result of severe blood loss. Petitioners filed an action against the United States under the Federal Tort Claims Act (FTCA). The federal district court found the United States liable under the FTCA. The court concluded that Petitioners’ economic damages amounted to $980,462 and Petitioners’ noneconomic damages totaled $2 million. However, the district court limited Petitioners’ recovery of wrongful death noneconomic damages to $1 million after applying Fla. Stat. 766.118, Florida’s statutory cap on wrongful death noneconomic damages based on medical malpractice claims. The district court subsequently denied Petitioners’ motion challenging the constitutionality of the wrongful death statutory cap. The Eleventh Circuit Court of Appeals affirmed the application of the statutory cap on noneconomic damages and held that the statute was not unconstitutional. The Florida Supreme Court accepted certification to answer questions of Florida law and answered by holding the statutory cap on wrongful death noneconomic damages provided in Fla. Stat. 766.118 violates the Equal Protection Clause of the Florida Constitution. View "Estate of McCall v. United States" on Justia Law