Justia Florida Supreme Court Opinion Summaries

The State charged Defendant with two drug-related offenses. Defendant rejected a twelve-year plea offer after being incorrectly advised that his maximum sentence was thirty years when, in fact, Defendant faced a maximum sentence of life in prison. After trial, Defendant was found guilty of simple sale of cocaine and possession of cocaine and was sentenced to thirty years imprisonment. The court of appeal affirmed, concluding that Defendant could not show prejudice because he ultimately received the same sentence as what he was incorrectly advised. Subsequent to the court of appeal's decision, the U.S. Supreme Court issued two decisions - Missouri v. Frye and Lafler v. Cooper - concerning ineffective assistance of counsel claims in which the defendant rejected a pea offer based on misadvice. In light of these two cases, the Florida Supreme Court receded from its decisions in Cottle v. State and Morgan v. State with respect to what a defendant must show in order to demonstrate prejudice. After clarifying what a defendant must show to demonstrate prejudice, the Court quashed the court of appeal's decision because it incorrectly analyzed the prejudice prong. Remanded. View "Alcorn v. State" on Justia Law

After a jury trial, Petitioner was convicted of first-degree murder under both premeditated and felony-murder theories. The trial court sentenced Petitioner to death. The Supreme Court affirmed Petitioner's conviction and sentence. Petitioner subsequently filed several motions for postconviction relief. This appeal concerned the denial of Petitioner's third successive motion for postconviction relief and a motion to vacate his death sentence or, in the alternative, a motion for an evidentiary hearing. Petitioner also filed a fifth state petition for writ of habeas corpus. The Supreme Court affirmed the circuit court's order dismissing Petitioner's motions, holding (1) Petitioner's claim of newly discovered evidence was without merit; (2) Petitioner's claim regarding his counsel on direct appeal was procedurally barred and without merit; and (3) Petitioner's claim of ineffective assistance of trial counsel during the penalty phase was procedurally barred. View "Van Poyck v. State" on Justia Law

After a jury trial in 2009, Defendant was convicted of second-degree murder and sentenced to life in prison. Defendant appealed, arguing that the trial court erred by instructing the jury on manslaughter by act and that the error was fundamental. The Second District Court of Appeal affirmed Defendant's conviction and sentence, concluding that the 2008 manslaughter by act instruction did not include an intent-to-kill element, which the Supreme Court found fundamentally erroneous in State v. Montgomery. However, the Second District certified that its decision conflicted with the with the decision of the First District in Riesel v. State. The Supreme Court quashed the decision of the Second District and approved the decision of the First District in Riesel, holding (1) the 2008 standard instruction for manslaughter by act erroneously required the jury to find Defendant intended to cause the death of the victim; and (2) the trial court fundamentally erred in giving the 2008 standard jury instruction in this case. Remanded for a new trial. View "Daniels v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and robbery with a deadly weapon. The trial court imposed a sentence of death. Defendant subsequently filed a postconviction motion, which was denied. Defendant appealed the denial of his motion and also filed a petition for writ of habeas corpus asserting ineffective assistance of appellate counsel. The Supreme Court affirmed, holding (1) the trial court did not err in finding Defendant's trial counsel was not ineffective for (i) deciding not to present the testimony of a mental health expert in the penalty phase to establish mental mitigation, (ii) failing to move for a change of venue, and (iii) failing to object to certain prosecutorial comments during the guilt phase closing argument; (2) Florida's capital sentencing scheme is constitutional; and (3) Defendant was not prejudiced by appellate counsel's failure to argue on direct appeal that the trial court improperly failed to assign weight to each mitigator and evaluate the relative weights of the aggravating and mitigating factors in its sentencing order. View "Taylor v. State" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death. With a minor exception, the Supreme Court denied Defendant's requests for postconviction relief and his petitions for writs of habeas corpus. In this postconviction action, Defendant filed a motion requesting postconviction DNA testing on six items collected by law enforcement in connection with the investigation of the victim's murder. Of these items, the State was only able to locate one of them. The circuit court summarily denied Defendant's motion. The Supreme Court affirmed, holding that there was no reasonable probability that Defendant would have been acquitted or received a lesser sentence if DNA evidence from any of the requested items had they been admitted at his trial. View "Jackson v. State" on Justia Law

Defendant pled guilty to several crimes, including grand theft and first-degree felony murder. The trial court imposed the death sentence. The Supreme Court affirmed Defendant's convictions but vacated his sentence and remanded for a new penalty phase. On remand, the trial court again sentenced Defendant to death. The Supreme Court affirmed. Defendant subsequently filed an amended motion for postconviction relief, which the trial court denied after a hearing. Defendant appealed and filed a petition for writ of habeas corpus. The Supreme Court affirmed, holding, inter alia, (1) Defendant failed to show his counsel was constitutionally deficient; (2) the postconviction court did not abuse its discretion in denying Defendant's motion to disqualify the postconviction court's judge; and (3) appellate counsel provided effective assistance. View "Farr v. State" on Justia Law

Two decisions of the Third District Court of Appeal were before the Supreme Court here. In the first case (Public Defender), the Public Defender for the Eleventh Judicial Circuit filed motions in several criminal cases seeking to be relieved of the obligations to represent indigent defendants in non-capital felony cases. The trial court permitted the Public Defender to decline appointments in future third-degree felony cases. The court of appeal reversed. In the second case (Bowens), an assistant public defender filed a motion to withdraw from representing a defendant, alleging that his excessive caseload created a conflict of interest. The circuit court granted the motion, but the court of appeal reversed. The Supreme Court (1) quashed the court of appeal's decision in Public Defender and remanded, holding (i) aggregate/systemic motions to withdraw are appropriate where there is an office-wide or widespread problem as to effective representation, and (ii) the Public Defender demonstrated cause for withdrawal in this case; and (2) quashed in part and affirmed in part the decision in Bowens, holding that Fla. Stat. 27.5303(1)(d) is facially constitutional but should not preclude a public defender from filing a motion to withdraw based on excessive caseload or underfunding that would result in ineffective representation of indigent clients. View "Public Defender, Eleventh Judicial Circuit of Fla. v. State" on Justia Law

Defendant pleaded guilty to two counts of first-degree murder and was sentenced to death in 1998 on both murder counts. The Supreme Court affirmed Defendant's convictions and death sentences. Defendant subsequently filed a postconviction motion and a number of amended motions. Defendant also filed a motion to withdraw his guilty plea. In 2008, the trial court granted Defendant a new penalty phase proceeding based on the claim of ineffective assistance of counsel during the penalty phase but denied the remaining claims and Defendant's motion to withdraw his guilty plea. Defendant appealed and also petitioned the Supreme Court for a writ of habeas corpus, claiming his death sentence was disparate and disproportionate based on newly discovered evidence. The Supreme Court (1) affirmed the trial court's order denying relief on the claims relating to Defendant's guilty plea and an alleged Brady violation and granting relief on the claim of ineffective assistance of counsel in the penalty phase; and (2) denied Defendant's petition for habeas relief, holding that the claim in the petition should have been raised in the postconviction motion at the trial court and was therefore procedurally barred. View "Griffin v. State" on Justia Law

Defendant was convicted of first-degree murder and sexual battery and sentenced to death. The Supreme Court affirmed Defendant's convictions and death sentence on direct appeal. Defendant subsequently filed a several post-conviction motions, which were ultimately unsuccessful. After the governor set a date for Defendant's execution, Defendant filed a successive postconviction motion, raising four claims. The circuit court summarily denied relief on all claims. The Supreme Court affirmed, holding (1) Defendant's claim that his mental illness should exempt him from execution was untimely and procedurally barred; (2) Defendant's claim that the death warrant selection process was arbitrary, thus rendering the death penalty unconstitutional, was without merit; (3) Defendant's claim that the clemency process he received was conducted in an arbitrary and capricious manner was without merit; and (4) Defendant's claim that adding execution to the "inordinate length of time" he spent on death row would constitute cruel and unusual punishment was without merit. View "Carroll v. State" on Justia Law

After a jury trial, Defendant was convicted of the 2001 first-degree murder of his wife. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant's conviction and sentence. Defendant subsequently filed a motion for postconviction relief, raising several claims. The circuit court denied relief. The Supreme Court affirmed, holding that the postconviction court correctly denied relief on Defendant's claims of ineffective assistance of trial counsel, as (1) counsel's failure to investigate and present evidence that Defendant had organic brain damage did not undermine confidence in the sentence; (2) counsel was not constitutionally deficient regarding the child witnesses who testified at Defendant's trial; and (3) counsel's failure to present evidence regarding the registration of the gun used in the homicide did not undermine confidence in Defendant's sentence; and (4) counsel made a reasonable strategic decision to have Defendant wear jail clothing during the penalty phase. View "Rodgers v. State" on Justia Law