Justia Florida Supreme Court Opinion Summaries

Petitioner, who was born in Nicaragua and entered the United States as a child, pleaded guilty to sale of a controlled substance, a second degree felony, in 2001. Following the U.S. Supreme Court's decision in Padilla v. Kentucky in 2010, Petitioner filed a postconviction motion alleging that his counsel failed to advise him that deportation was mandatory for the offense to which he pled guilty and that he would not have pled guilty if he had known that it would mandate his deportation without recourse. The circuit court denied Petitioner's motion on the basis that the immigration consequences warning included in the plea colloquy pursuant to Fla. R. Crim. P. 3.172(c)(8) precluded Petitioner from establishing the requisite prejudice under Strickland v. Washington. The Third District Court of Appeal upheld the denial of Petitioner's postconviction motion and then certified questions of law to the Florida Supreme Court. The Supreme Court answered (1) the immigration warning in Rule 3.172(c)(8) does not bar immigration-based ineffective assistance of counsel claims based on Padilla; and (2) however, the ruling in Padilla does not apply retroactively. Therefore, the Court approved of the Third District's decision upholding the denial of Petitioner's postconviction motion. View "Hernandez v. State" on Justia Law

Appellant appealed from a judgment of conviction of first-degree murder and a sentence of death for the killing of Andrea Boyer, as well as a conviction for sexual battery by use of actual physical force likely to cause serious personal injury. The Supreme Court reversed the convictions, vacated the sentence of death, and remanded for a new trial, holding that reversible error occurred in the guilt phase of the trial, when the State introduced a lengthy videotape of Appellant's custodial interrogation in which the investigating officers repeatedly expressed their personal opinions about Appellant's guilt and the victim's character and family life. View "Jackson v. State" on Justia Law

Appellant appealed his first-degree murder conviction and sentence of death for the killing of Quatisha Maycock, as well as his convictions and sentences for related offenses. The Supreme Court affirmed Appellant's convictions and sentences, holding, among other things, (1) the trial court did not err in denying Appellant's motion to suppress the statements he made to police officers, all post arrest / custody observations of Appellant made by police officers, and evidence seized from Appellant; (2) the trial court did not err in denying Appellant's two motions to disqualify; (3) the prosecutor's comments during closing argument and made during the State's penalty phase closing argument did not rise to the level of fundamental error; (4) the evidence introduced at trial was sufficient to support Appellant's convictions for burglary, child neglect, and attempted escape; (5) The trial court did not err by requiring Appellant to argue all of his nonstatutory mitigating evidence as a single mitigating factor; (6) the trial court did not err by allowing the State to introduce at Appellant's penalty phase trial evidence of his prior violent felony convictions; and (7) Appellant's sentence was proportionate to death sentences that the Court has upheld in other cases. View "Braddy v. State" on Justia Law

Defendant was tried and convicted for the murder of a five-month-old. Defendant was sentenced to death. The Supreme Court affirmed his convictions and sentence of death but remanded for resentencing on the aggravated child abuse conviction. Defendant subsequently filed a motion to vacate judgment and sentence. The lower court denied Defendant's claims. Defendant then appealed, asserting that his counsel was ineffective. The Supreme Court denied the appeal. Thereafter, Defendant filed a successive motion to vacate judgment and sentence with special request for leave to amend, asserting that his counsel was ineffective. The circuit court summarily denied the motion and subsequent rehearing. The Supreme Court affirmed, holding (1) because Defendant's motion was untimely, the postconviction court properly summarily denied the motion; and (2) because Defendant did not address the merits of his claim on appeal, and because the postconviction court did not rule on the merits, the Court would not reach the merits of his claim. View "Lukehart v. State" on Justia Law

Defendant was tried, convicted, and sentenced for several crimes against four separate victims. Two of the victims - Iris White and Jackie McCahon - were murdered, while two were not. This appeal stemmed from Defendant's first-degree murder conviction and accompanying death sentence for the killing of Jackie McCahon. Defendant raised thirteen claim on direct appeal. The Supreme Court denied each of Defendant's claims, determined that the death penalty was proportional to Defendant's crime, and affirmed Defendant's convictions and sentences. Defendant subsequently filed a motion for postconviction relief, raising sixteen claims. The postconviction court ultimately denied all of Defendant's claims. The Supreme Court affirmed, holding that Defendant was not entitled to postconviction relief from his conviction and sentence for the first-degree murder of McCahon. View "Johnson v. State " on Justia Law

Defendant was tried, convicted, and sentenced for several crimes against four separate victims. Two of the victims - Iris White and Jackie McCahon - were murdered, while two were not. This appeal stemmed from Defendant's first-degree murder conviction and accompanying death sentence for stabbing Iris White to death inside her home. The Supreme Court denied each of Defendant's claims on appeal, found the death penalty to be proportionally warranted, and affirmed Defendant's convictions and sentences. Defendant subsequently filed a motion for postconviction relief, raising twenty claims. Ultimately, the postconviction court denied Defendant's postconviction motion in its entirety. The Supreme Court affirmed the circuit court's denial of Defendant's motion for postconviction relief, holding that Defendant was not entitled to postconviction relief from his conviction and sentence for the first-degree murder of White. View "Johnson v. State" on Justia Law

Petitioner was convicted by a jury of two counts of lewd and lascivious acts on a minor. The court of appeal reversed and remanded for a new trial. At Petitioner's second trial, the trial court partially closed the courtroom during the testimony of the victim pursuant to Fla. Stat. 918.16(2), which provided for partial closure of the courtroom during the testimony of a victim of a sex offense upon the victim's request. Appellant was again convicted of the charges. The court of appeals affirmed Appellant's convictions. The Supreme Court affirmed, holding (1) Appellant was not denied his right to a public trial by the trial court's partial closure during the victim's testimony; and (2) a partial closure pursuant to section 918.16(2) acceptably embraces the requirements set forth in the U.S. Supreme Court's decision in Waller v. Georgia. View "Kovaleski v. State" on Justia Law

Defendant appealed an order of the circuit court denying his initial postconviction motion filed under Fla. R. Crim. P. 3.851 to vacate his conviction of first-degree murder and sentence of death. Defendant also petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court (1) affirmed the postconviction court's denial of relief as to Defendant's guilt phase claims; (2) reversed the denial of relief as to the penalty phase and remanded for a new penalty phase proceeding because counsel failed to fully investigate and present mitigating evidence regarding Defendant's childhood and mental health; and (3) denied Defendant's petition for writ of habeas corpus. View "Simmons v. State" on Justia Law

Defendant appealed an order entered by the circuit court finding him competent to be executed. Defendant's primary argument on appeal was that the circuit court improperly found him sane to be executed based on its finding that his delusions were a manifestation of a normal Christian belief, and alternatively, that the circuit court's determination was a misapplication of the standard pronounced in the United States Supreme Court's decision in Panetti v. Quarterman. The Supreme Court affirmed the circuit court's order finding Defendant sane to be executed, holding (1) there was competent, substantial evidence to support the circuit court's determination that Defendant was sane to be executed; (2) Defendant's argument concerning Panetti was without merit; and (3) Defendant's due process claims were without merit. View "Ferguson v. State" on Justia Law

Appellant, a prisoner under sentence of death, appealed the circuit court's order denying his second successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851 and the order denying his motion for competency determination. The Supreme Court affirmed, holding (1) Appellant's claim that Florida's lethal injection statute violates the Separation of Powers Doctrine was time-barred; (2) the circuit court properly found Appellant's claim that the clemency proceeding did not comport with due process was time-barred; (3) the circuit court properly denied Appellant's claim that, as applied, Florida's death warrant selection process was unconstitutional; (4) Appellant's argument that his punishment was unconstitutional because he was incarcerated on death row for over three decades failed; and (5) the circuit court did not err in denying Appellant's motion for competency determination. View "Ferguson v. State" on Justia Law