Justia Florida Supreme Court Opinion Summaries

This case was before the Supreme Court on appeal from a judgment of conviction of first-degree murder and a sentence of death. The Supreme Court affirmed Appellant's conviction but remanded for a new penalty phase, holding, inter alia, (1) the trial court erred in admitting certain testimony from Appellant's wife, as the communications reflected in the testimony were privileged, but the error was harmless beyond a reasonable doubt; (2) the trial court should have granted Appellant's motion for judgment of acquittal on the charge of attempted sexual battery, but the error did not require a new trial; (3) the trial court's finding of the cold, calculated, and premeditated aggravator was error; and (4) based on the number of errors during the penalty phase, the errors were not harmless. View "Kaczmar v. State" on Justia Law

Petitioner, a juvenile placed on juvenile probation, pleaded guilty to failing to follow an order of probation by violating curfew and failing to obey household rules. The circuit court then placed Petitioner in secure detention. Petitioner subsequently filed a petition for writ of habeas corpus, arguing that his sentence was illegal. The second district court of appeal denied Petitioner's petition for writ of habeas corpus and certified conflict with the fifth district court of appeal's decision in M.P. v. State. The Supreme Court (1) approved the decision of the second district court of appeal denying Petitioner's petition for writ of habeas corpus, and (2) disapproved the decision of the fifth district court of appeal in M.P. to the extent it was inconsistent with this opinion. View "J.M. v. Gargett" on Justia Law

In 2005, Petitioner was convicted and sentenced for committing two sex offenses. Since 2009, Petitioner, an inmate in state custody, had filed six previous extraordinary writ petitions with the Supreme Court seeking various forms of relief related to his convictions or sentences. Each of Petitioner's extraordinary writ petitions filed with the Supreme Court was devoid of merit or inappropriate for consideration. Therefore, the Court issued an order directing Petitioner to show cause why he should not be prohibited from filing any subsequent pro se filings in the Court regarding his convictions. After considering Petitioner's response, the Court concluded that it failed to show cause why sanctions should not be imposed. In the meantime, Petitioner filed a pro se petition for writ of habeas corpus with the Supreme Court alleging that his sentences were illegal. The Court further concluded that Petitioner's procedurally barred petition filed in this case was a frivolous proceeding brought before the Court by a state prisoner, and accordingly, the Clerk of Court was instructed to reject any future pleadings, petitions, motions, documents, or other filings submitted by Petitioner regarding his convictions. View "Green v. Tucker" on Justia Law

After a jury trial, Petitioner was convicted of first-degree murder, second-degree murder, and burglary of a dwelling during which a battery upon the victims was committed while Petitioner was armed with a weapon. The trial court sentenced Petitioner to death for the first-degree murder convictions. Petitioner subsequently filed a motion to vacate his convictions of first-degree murder and sentences of death under Fla. R. Crim. P. 3.851. The circuit court denied the motion. Petitioner appealed and petitioned the Supreme Court for a writ of habeas corpus. The Court affirmed the denial of the Rule 3.851 motion, and denied Petitioner's petition for a writ of habeas corpus, concluding that no reversible error occurred and that defense counsel did not perform ineffectively. View "Reynolds v. Tucker" on Justia Law

Appellant was a prisoner under sentence of death. After the Supreme Court affirmed Appellant's death sentence on direct appeal. D. Todd Doss was appointed as counsel for Appellant for Appellant's postconviction proceedings. Thereafter, Appellant sought to discharge Doss as postconviction counsel and waive the postconviction proceedings. The circuit court found Appellant competent and issued an order discharging Doss and dismissing the proceedings. Doss, on behalf of Appellant, appealed. The Supreme Court affirmed, holding (1) Appellant was afforded constitutionally adequate competency, waiver of postconviction, and discharge of counsel proceedings; and (2) the circuit court did nor err in finding Appellant competent to waive postconviction proceedings and to discharge counsel. View "Gill v. State" on Justia Law

Appellant was convicted of first-degree murder, false imprisonment as a lesser included offense of kidnapping, armed robbery with a deadly weapon, and grand theft of a motor vehicle. A jury recommended a sentence of death. The trial court accepted that recommendation and sentenced Appellant to death. The Supreme Court affirmed the findings and underlying judgment of guilty in the trial court but reversed and remanded for the limited purpose of requiring the trial court to perform a new sentencing evaluation because the analysis of the mitigating circumstances in the trial court's sentencing order did not meet the requirements articulated in Campbell v. State. View "Oyola v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and armed robbery and sentenced to death. The Supreme Court affirmed Appellant's convictions and sentence, holding (1) Appellant's statement to police was properly admitted into evidence, and police did not violate the Fifth Amendment in obtaining the statement; (2) Appellant's confession was voluntary, and contrary to Appellant's contention, the confession was not coerced by detectives; (3) the trial court did not err in finding the aggravating factor of cold, calculated, and premeditated to be established in Appellant's capital murder prosecution; (4) the trial court did not err in finding that Appellant did not prove the mitigating factors of emotional abuse, sexual abuse, and remorse; (5) the trial court did not overlook any material evidence in considering the aggravating and mitigating factors; (6) Appellant's constitutional challenge to Florida's death sentencing scheme was without merit; (7) Appellant's sentence of death was proportionate; and (8) there was sufficient evidence to support Appellant's convictions. View "Martin v. State" on Justia Law

The State charged Defendant, who at the time was detained at a juvenile detention center, with one count of battery by detainee in violation of Fla. Stat. 784.03 and 784.082. Defendant moved to dismiss the charge, contending that a juvenile could not be lawfully charged with battery by detainee while detained in a juvenile detention facility. The trial court dismissed the charge based on its belief that it was bound to follow the first district court of appeal's decision in T.C. v. State, which held that the battery by detainee offense was inapplicable to juveniles held in juvenile facilities. The fourth district court of appeals reversed, noting that in the past it and the fifth district had affirmed a trial court order adjudicating a juvenile guilty of battery upon a fellow detainee. The Supreme Court affirmed, holding that a juvenile detention center qualifies as a "detention facility" for purposes of section 784.082, and thereby disapproving the first district's decision in T.C. View "Hopkins v. State" on Justia Law

Petitioner was convicted of the 1999 sexual battery and first-degree murder of an eighteen-year-old and sentenced to death. The Supreme Court affirmed his convictions and sentences. Petitioner subsequently appealed the denial of his motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851 and simultaneously petitioned for a writ of habeas corpus. The Supreme Court affirmed the postconviction court's denial of relief and denied Petitioner's habeas petition, holding (1) Defendant failed to carry his burden of demonstrating he was prejudiced by trial counsel's deficient performance in preparation for the penalty phase; (2) Rule 3.851, which imposes a one-year time limit for filing motions for postconviction relief, is not unconstitutional; (3) Florida's capital sentencing statute is not unconstitutional; and (4) certain omissions by his appellate counsel on direct appeal did not constitute ineffective assistance of appellate counsel. View "Douglas v. Tucker" on Justia Law

Defendant was charged with second-degree murder and was convicted as charged. The court of appeal affirmed. Defendant subsequently petitioned for writ of habeas corpus, arguing that his appellate counsel was ineffective for failing to raise a claim of fundamental error when the jury was instructed on manslaughter by intentional act as a lesser included offense. The third district court of appeal certified conflict with the decision of the first district court of appeal in Montgomery v. State. The Supreme Court stayed proceedings pending disposition of Montgomery. In Montgomery, the Court held that the use of the then-standard jury instruction on the lesser included offense of manslaughter by act constituted fundamental error in Montgomery's case because the instruction erroneously required the jury to find that the defendant intentionally caused the death of the victim. After the Court lifted the stay in the instant case, the Court quashed the decision under review and remanded the matter to the court of appeal for reconsideration upon application of its decision in Montgomery. View "Leggett v. State" on Justia Law