Justia Florida Supreme Court Opinion Summaries

In this case, the defendant was convicted of first-degree murder and robbery with a firearm for the 1991 killing of a police officer during a traffic stop. After initial convictions and a direct appeal, a new penalty phase was ordered, and the defendant was again sentenced to death in 1996. The trial court found two aggravating factors, including that the murder was committed during a robbery and to hinder law enforcement, outweighing the mitigating circumstances related to the defendant’s age, confession, courtroom behavior, and difficult childhood. The Florida Supreme Court affirmed the convictions and death sentence, which became final in 2001. Over the following decades, the defendant pursued numerous unsuccessful challenges to the conviction and sentence in state and federal courts.Following the signing of a death warrant in January 2026, the defendant filed a sixth successive motion for postconviction relief in the Circuit Court for St. Lucie County. He raised three claims: newly discovered evidence of jury influence by uniformed officers, a claim of intellectual disability based on a recent IQ test, and a challenge to the constitutionality of Florida’s death warrant process. The circuit court summarily denied all claims, as well as related motions for a juror interview, to declare the intellectual disability standard unconstitutional, and for late-filed public records requests.On review, the Supreme Court of Florida affirmed the circuit court’s denial of postconviction relief, denied the habeas corpus petition, and denied the motions for a stay of execution. The Court held that the claims of improper jury influence and intellectual disability were untimely and procedurally barred, the request for a juror interview and public records were properly denied as untimely and speculative, and that the intellectual disability claim was also legally insufficient. The Court further declined to extend Eighth Amendment protections beyond current U.S. Supreme Court precedent. View "Kearse v. State" on Justia Law

On a December morning in 2008, a house fire in Green Cove Springs, Florida, led to the discovery of Maria Ruiz’s burned and bloodied body. The home had recently been occupied by Leo Louis Kaczmar III, his family members, and Ruiz. Investigators found gasoline was used to start the fire. Kaczmar arrived at the scene, presenting a gas receipt and claiming he had been fishing, but admitted being alone with Ruiz in the hours before the fire. Post-indictment, Kaczmar discussed his case with fellow inmate William Filancia, who later worked with law enforcement. Undercover Detective Humphrey posed as "Carlos" to elicit incriminating statements from Kaczmar.At trial in the Circuit Court, the State presented extensive evidence, including witness testimony, video showing Kaczmar purchasing gasoline before the fire, and DNA evidence linking Ruiz’s blood to Kaczmar’s sock. Kaczmar’s defense called one witness regarding his truck’s search. The jury convicted Kaczmar of murder, arson, and attempted sexual battery, recommending death. The Florida Supreme Court affirmed the conviction but reversed the death sentence due to insufficient proof on aggravating factors, remanding for a new penalty phase. At resentencing, the jury unanimously recommended death, and the court imposed it. This was affirmed on appeal, with a rehearing denied.Kaczmar then sought postconviction relief in the circuit court, alleging ineffective counsel and various due process violations. The circuit court vacated his death sentence based on counsel’s failure to object to the judge’s mention of a prior death sentence, but denied all other claims. On appeal, the Supreme Court of Florida reversed the grant of penalty-phase relief, finding no prejudice from the judge’s statement, and affirmed denial of all other claims. Kaczmar’s habeas petition was also denied. The Court ordered reinstatement of his death sentence. View "State of Florida v. Kaczmar" on Justia Law

The case concerns Melvin Trotter, who was convicted of the 1986 first-degree murder of Virgie Langford, a 70-year-old store owner. Trotter stabbed and robbed Langford, resulting in her death several hours after emergency surgery. Following a jury’s recommendation, Trotter was sentenced to death; this sentence was initially reversed, but after a new penalty phase, the trial court again imposed the death penalty, finding multiple aggravating factors and both statutory and nonstatutory mitigation. Trotter’s conviction and sentence became final in 1997, and he has unsuccessfully challenged his death sentence in various state and federal courts since then.After the Governor signed his death warrant in January 2026, Trotter filed a successive motion for postconviction relief and a motion for stay of execution in the Circuit Court for Manatee County. He raised two claims: first, that alleged failures by the Florida Department of Corrections to follow lethal injection procedures violated his constitutional rights, and second, that executing him at age 65 constituted cruel and unusual punishment due to his advanced age. The circuit court summarily denied both claims and denied the stay of execution.On appeal, the Supreme Court of Florida reviewed the circuit court’s summary denial de novo. The Court held that Trotter’s claims regarding lethal injection procedures were speculative and failed to demonstrate a substantial and imminent risk of serious harm, nor did he identify an alternative method of execution as required by precedent. The Court also rejected Trotter’s argument for a categorical exemption from execution based on age, reaffirming prior holdings that only those under 18 at the time of the crime are exempt. The Supreme Court of Florida affirmed the circuit court’s denial of postconviction relief, denied Trotter’s habeas petition as procedurally barred and lacking merit, and declined to stay the execution. View "Trotter v. State" on Justia Law

Ronald Heath was sentenced to death for the 1989 murder of Michael Sheridan in Alachua County, Florida. Heath and his brother Kenneth conspired to rob Sheridan after meeting him at a bar, and the crime escalated when Heath stabbed Sheridan and instructed Kenneth to shoot him. Evidence at trial included testimony from Kenneth and physical evidence linking Heath to the victim’s property. The jury convicted Heath of first-degree murder and related offenses, recommending death by a vote of ten to two. The trial court imposed the death sentence, finding aggravating circumstances outweighed mitigating factors.Following affirmance of his conviction and sentence by the Supreme Court of Florida and denial of certiorari by the United States Supreme Court, Heath pursued multiple postconviction challenges in state and federal courts, all of which were unsuccessful. After his death warrant was signed in January 2026, Heath filed a second successive motion for postconviction relief in the Circuit Court of Alachua County. He raised claims regarding Florida’s lethal injection protocol, secrecy in clemency proceedings, his psychological age due to traumatic incarceration, and the nonunanimous jury recommendation. The circuit court summarily denied all claims and associated public records requests.The Supreme Court of Florida reviewed Heath’s appeal and habeas petition. It affirmed the circuit court’s summary denial of postconviction relief and public records requests, finding Heath’s claims were either speculative, procedurally barred, untimely, or insufficient under relevant legal standards. The Court held Heath failed to demonstrate a substantial and imminent risk with the execution protocol, did not raise a colorable clemency claim, and was not entitled to relief based on psychological age or nonunanimous jury vote. The Court also denied Heath’s habeas petition and his motion for a stay of execution. View "Ronald Palmer Heath v. State of Florida" on Justia Law

A nonprofit research foundation affiliated with a state university entered into a memorandum of understanding (MOU) with the university in 2007, becoming a statutorily regulated direct-support organization (DSO). The MOU provided that the foundation’s board would include two appointees from the university but was otherwise silent on board approval and on budget approval processes. In 2018, the Florida Legislature enacted a law requiring all DSO board appointments to be approved by the university’s board of trustees. Around the same time, a regulation by the Board of Governors (BOG) required university boards of trustees to approve DSO budgets. The foundation challenged these requirements, arguing that they impaired its contractual rights under the MOU.The Circuit Court conducted a trial and found that the MOU limited the university’s involvement to only the two appointees and that the statutory board approval requirement impaired the MOU. It concluded that the university failed to show a significant and legitimate public purpose for the statute. However, regarding the budget approval dispute, the court held that the MOU did not address budget approval, so there was no contractual impairment. The Fourth District Court of Appeal affirmed both findings, concluding that the statutory board approval requirement rewrote the parties’ contract, while the regulation on budget approval did not impair the MOU.The Supreme Court of Florida reviewed the case. It held that the MOU only addressed the university’s power to appoint two board members and was silent on approval of other appointments or on budget approval. Therefore, the statutory and regulatory changes did not impair any specific contractual obligations. The court reversed the Fourth District’s ruling on the board appointment issue and otherwise affirmed, holding that neither the statute nor the regulation unconstitutionally impaired the MOU. View "Florida Atlantic University Board of Trustees v. Harbor Branch Oceanographic Institute Foundation, Inc." on Justia Law

In 2010, a woman was found dead in her Jacksonville, Florida apartment, having been stabbed approximately ninety times. The investigation led law enforcement to question the defendant, who initially denied involvement but ultimately confessed to the killing and to taking items from the apartment. He was charged with first-degree murder. At trial in Duval County, a jury found him guilty, and after a penalty-phase proceeding where the defendant declined to present additional mitigating evidence, the jury unanimously recommended a death sentence. The trial court imposed the death penalty, finding the aggravating factors outweighed the mitigating circumstances.The Florida Supreme Court previously affirmed his conviction and sentence on direct appeal. Subsequent challenges included an initial postconviction motion, a state habeas petition, and a first successive postconviction motion, all of which were denied. While the first successive motion was pending, the defendant filed a second successive postconviction motion in the state circuit court, raising new constitutional claims related to the representativeness of his jury. He relied on a recent academic study to argue that his jury was not drawn from a fair cross-section of the community. The circuit court summarily denied the motion as untimely and meritless.The Supreme Court of Florida reviewed the appeal from the circuit court’s summary denial. The court held that the claims were untimely under rule 3.851, as the academic study did not constitute newly discovered evidence. Additionally, the claims were procedurally barred because they could have been raised earlier. The court also found the Sixth, Eighth, and state constitutional claims to be legally insufficient, clarifying that the fair cross-section requirement applies to the jury pool, not the petit jury. The denial of postconviction relief was affirmed. View "David Kelsey Sparre v. State of Florida" on Justia Law

In 1996, Samuel Smithers was hired to maintain a 27-acre property in Plant City, Florida, where two women, Cristy Cowan and Denise Roach, were found murdered near the property’s ponds. Evidence, including DNA and surveillance footage, linked Smithers to the victims. After being questioned by law enforcement, Smithers gave inconsistent statements and ultimately confessed to both murders. At trial, medical testimony established that both victims died from a combination of strangulation and wounds inflicted by a sharp instrument. Smithers testified in his own defense, blaming an unknown man for the crimes, but the jury convicted him of two counts of first-degree murder and unanimously recommended the death penalty for both.The Circuit Court for Hillsborough County sentenced Smithers to death, finding several aggravating factors and weighing mitigating circumstances. The Florida Supreme Court affirmed his convictions and sentences on direct appeal. Smithers subsequently filed multiple postconviction motions and federal habeas petitions, all of which were denied by the respective courts, including the United States Supreme Court’s denial of certiorari. In 2025, after the Governor signed his death warrant, Smithers filed a successive postconviction motion arguing that executing him at age 72 would constitute cruel and unusual punishment due to his advanced age.The Supreme Court of Florida reviewed the summary denial of Smithers’ motion. The court held that his claim was untimely and procedurally barred under Florida Rule of Criminal Procedure 3.851, as none of the rule’s exceptions applied. Additionally, the court concluded that Florida’s conformity clause requires its courts to follow United States Supreme Court precedent, which does not recognize a categorical exemption from execution based on advanced age. Therefore, the Supreme Court of Florida affirmed the circuit court’s summary denial of Smithers’ successive postconviction motion. View "Smithers v. State" on Justia Law

In 2009, after a history of domestic violence and threats, the defendant killed his wife and five young children by cutting their throats and then fled to Haiti, where he was apprehended and confessed. He attributed his actions to “bad spirits” and voodoo spells. Upon return to Florida, he pled guilty to six counts of first-degree murder, waived his right to a penalty-phase jury, and declined to present mitigation evidence. Throughout the proceedings, his competency to stand trial was repeatedly evaluated, with findings alternating between competent and incompetent, but ultimately he was found competent at the time of his plea and sentencing. His defense team, which included both public defenders and later court-appointed attorneys, conducted extensive mitigation investigations, including mental health and cultural background assessments, despite the defendant’s lack of cooperation.The Circuit Court for Collier County imposed six death sentences, finding multiple aggravating factors and twelve mitigating factors, including some evidence of mental illness. On direct appeal, the Supreme Court of Florida affirmed the convictions and sentences, rejecting claims regarding self-representation, aggravator duplication, and the constitutionality of the death penalty. The defendant then filed a motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, raising claims of ineffective assistance of counsel related to competency and mitigation, and challenging restrictions on access to public records. The circuit court denied all claims after an evidentiary hearing.The Supreme Court of Florida reviewed the appeal from the denial of postconviction relief and a related habeas corpus petition. The court held that claims regarding competency were procedurally barred, as they could have been raised on direct appeal, and that the defendant failed to show ineffective assistance of counsel under the Strickland standard. The court also found no abuse of discretion in the denial of public records requests and rejected the habeas petition alleging ineffective assistance of appellate counsel. The court affirmed the denial of postconviction relief and denied habeas corpus relief. View "Damas v. State of Florida" on Justia Law

In December 1990, Victor Tony Jones fatally stabbed his employers, Jacob and Matilda Nestor, during a robbery at their business in Miami-Dade County. Jones was found at the scene with the victims’ belongings and admitted to the killings at the hospital. He was convicted by a jury of two counts of first-degree murder and two counts of armed robbery. The trial court, following the jury’s recommendation, imposed death sentences for both murders, citing three aggravating factors and no mitigation. The Florida Supreme Court affirmed the convictions and sentences, and the United States Supreme Court denied certiorari in 1995.Over the following decades, Jones filed multiple unsuccessful motions for postconviction relief in the Circuit Court for Miami-Dade County and petitions for habeas corpus in state and federal courts. After Governor Ron DeSantis signed Jones’s death warrant in August 2025, Jones filed a sixth successive motion for postconviction relief, arguing newly discovered evidence of abuse at the Okeechobee School for Boys, racial disparities in Miami-Dade capital prosecutions, and due process violations in the warrant process. He also made post-warrant demands for public records related to the Okeechobee School. The circuit court summarily denied all claims and records requests.The Supreme Court of Florida reviewed the appeal and petition. It held that Jones’s claim of newly discovered evidence regarding abuse at the Okeechobee School was procedurally barred and meritless, as the alleged abuse was known to Jones long before trial and did not constitute evidence likely to yield a life sentence on retrial. The court also found no due process violation in the warrant process and no abuse of discretion in denying Jones’s public records requests. The habeas petition was denied as an improper attempt to relitigate previously decided issues. The court affirmed the circuit court’s orders, denied all relief, and refused to entertain any rehearing. View "Jones v. State" on Justia Law

The case involves a challenge to Florida’s 2022 congressional districting plan. The plaintiffs, consisting of civic organizations and individual voters, argue that the plan violates the Florida Constitution's Fair Districts Amendment (FDA) by failing to retain a two-hundred-mile-long congressional district that previously enabled black voters in North Florida to elect representatives of their choice. The plaintiffs claim that the new plan diminishes this ability, contrary to the FDA's Non-Diminishment Clause.The trial court ruled in favor of the plaintiffs, declaring the Enacted Plan unconstitutional under the FDA, enjoining its use, and ordering the Legislature to adopt a remedial map. The First District Court of Appeal reversed this decision, holding that the plaintiffs failed to prove the existence of a sufficiently compact minority community in North Florida to merit protection under the FDA. The appellate court also questioned the binding nature of the Florida Supreme Court’s precedents on the Non-Diminishment Clause.The Supreme Court of Florida reviewed the case and upheld the Enacted Plan. The court concluded that the plaintiffs did not meet their burden of proving the possibility of drawing a North Florida district that complies with both the Non-Diminishment Clause and the Equal Protection Clause. The court emphasized that compliance with the Equal Protection Clause is a superior obligation and that the plaintiffs failed to demonstrate that a non-diminishing district could be drawn without subordinating traditional race-neutral districting principles to racial considerations. Consequently, the court affirmed the judgment of the First District Court of Appeal, though not its reasoning. View "Black Voters Matter Capacity Building Institute, Inc. v. Secretary, Florida Department of State" on Justia Law