Justia Florida Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Smithers v. State
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
Posted in:
Constitutional Law, Criminal Law
Damas v. State of Florida
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
Posted in:
Constitutional Law, Criminal Law
Jones v. State
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
Posted in:
Constitutional Law, Criminal Law
Black Voters Matter Capacity Building Institute, Inc. v. Secretary, Florida Department of State
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
Posted in:
Constitutional Law, Election Law
Williams v. State of Florida
An individual was convicted of the 2010 first-degree felony murder of an elderly woman, Janet Patrick, after being seen with her at a grocery store and later found in possession of her car and credit cards. The victim’s body was discovered in a wooded area, and forensic evidence linked the defendant to the crime scene and the victim’s vehicle. The defendant was also charged with robbery and kidnapping. His defense at trial was based on claims of mental illness or seizures. The jury found him guilty on all counts.The Florida Supreme Court previously affirmed the convictions and non-capital sentences but reversed the death sentence because the jury’s recommendation was not unanimous, as required by Hurst v. State. After subsequent legal developments, including State v. Poole and State v. Okafor, the defendant was granted a new penalty phase. During the new penalty phase, the defendant represented himself, waived a jury trial, and declined to present mitigation evidence. The trial court denied his motion for a continuance to secure a new mitigation specialist, finding that he had been given multiple opportunities to obtain such assistance. The court ultimately sentenced him to death, finding four aggravating factors and several mitigating circumstances.On direct appeal, the Supreme Court of Florida reviewed four claims: denial of the motion to continue, voluntariness of waivers of jury and mitigation, access to discovery, and the constitutionality of Florida’s death penalty scheme. The court held that the trial court did not abuse its discretion in denying the continuance, that the waivers were knowing and voluntary, that discovery obligations were met, and that the capital sentencing scheme was constitutional. The court affirmed the sentence of death. View "Williams v. State of Florida" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Rogers v. State
In 1995, Glen Edward Rogers murdered Tina Marie Cribbs in Hillsborough County, Florida. Rogers was convicted of first-degree murder, armed robbery, and grand theft of a motor vehicle. He was sentenced to death, and his conviction and sentence were affirmed on direct appeal. Rogers has since filed multiple postconviction motions, all of which have been denied.Rogers' fourth successive postconviction motion raised three claims: (1) he was unconstitutionally deprived of the right to challenge his conviction and sentence due to a conflict of interest with his counsel, (2) newly discovered evidence of his childhood sexual abuse and trafficking would result in a life sentence on remand, and (3) Florida’s lethal injection procedures are cruel and unusual due to his porphyria diagnosis. The postconviction court summarily denied these claims as untimely, procedurally barred, and/or meritless.The Supreme Court of Florida reviewed the case and affirmed the postconviction court's denial. The court found that Rogers' conflict-of-counsel claim was procedurally barred and without merit, as there was no actual conflict of interest. The newly discovered evidence claim was also found to be procedurally barred and meritless, as the evidence could have been discovered with due diligence. Lastly, the court held that Rogers' method-of-execution claim was untimely and meritless, as he failed to demonstrate that Florida’s lethal injection protocol would cause him substantial and imminent risk of serious illness and needless suffering, and he did not identify a viable alternative method of execution.The Supreme Court of Florida denied Rogers' motion for a stay of execution and his request for oral argument, affirming the summary denial of his fourth successive postconviction motion. View "Rogers v. State" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Hutchinson v. State
Jeffrey G. Hutchinson was convicted of murdering his girlfriend Renee Flaherty and her three children in 1998. After an argument with Renee, Hutchinson drank heavily, returned to her home with a shotgun, and killed Renee and two of her children with single shots to the head. He then shot the third child, Geoffrey, twice, killing him. Hutchinson called 911, admitting to the shootings, and was found by police with gunshot residue on his hands and body tissue from Geoffrey on his leg. He was charged with four counts of first-degree murder and sentenced to death for the murders of the three children.Hutchinson's convictions and death sentences were affirmed on direct appeal by the Florida Supreme Court. He filed multiple postconviction motions, all of which were denied. His initial state postconviction motion and successive motions were also denied, as were his federal habeas petitions. His fourth successive postconviction motion, filed after the Governor signed a death warrant, was denied by the circuit court without an evidentiary hearing.The Supreme Court of Florida reviewed Hutchinson's appeal of the denial of his fourth successive postconviction motion and his habeas corpus petition. The court affirmed the circuit court's denial, rejecting Hutchinson's claims that the warrant period violated his constitutional rights, that the warrant selection process was arbitrary, and that his execution would be cruel and unusual punishment. The court also denied his habeas claims, including his argument that Atkins v. Virginia should extend to individuals with neurocognitive disorders and his challenge to the heinous, atrocious, or cruel (HAC) aggravator. The court denied Hutchinson's requests for a stay and oral argument, and ordered the mandate to issue immediately. View "Hutchinson v. State" on Justia Law
Tanzi v. State
Michael A. Tanzi was sentenced to death for the murder of Janet Acosta. On March 10, 2025, Governor Ron DeSantis signed a death warrant scheduling Tanzi’s execution for April 8, 2025. Tanzi sought relief in the circuit court, which was denied, leading to his appeal to the Supreme Court of Florida.The circuit court had previously denied Tanzi’s first motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, and the Florida Supreme Court affirmed this denial. Tanzi’s petition for state habeas relief was also denied. He then sought federal habeas relief, which was denied by the district court and affirmed by the Eleventh Circuit. Tanzi’s subsequent motion for postconviction relief under Hurst v. Florida was denied by the Florida Supreme Court, which found the Hurst error in his case harmless beyond a reasonable doubt.The Supreme Court of Florida reviewed Tanzi’s appeal of the denial of his third motion for postconviction relief, which raised claims about due process violations due to the compressed warrant period, the constitutionality of Florida’s lethal injection protocols, and the Governor’s authority in determining the timing of death warrants. The court affirmed the circuit court’s summary denial of these claims, finding them either procedurally barred or without merit. The court also denied Tanzi’s habeas petition, which argued that his death sentence was unconstitutional under Erlinger v. United States, and dismissed his emergency petition to invoke the court’s all writs jurisdiction.The Supreme Court of Florida held that the warrant litigation schedule did not violate Tanzi’s due process rights, the denial of public records requests was not an abuse of discretion, and the lethal injection protocol did not constitute cruel and unusual punishment. The court also upheld the Governor’s authority in signing death warrants and found no merit in Tanzi’s habeas petition. The court denied all of Tanzi’s motions and requests, including a stay of execution. View "Tanzi v. State" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Vericker v. Powell
Kevin Vericker published an internet blog questioning the credentials, character, and competency of Norman Christopher Powell, who was appointed as the attorney for North Bay Village. Powell filed a defamation lawsuit against Vericker, claiming the blog posts were defamatory per se. Vericker responded with a motion for summary judgment and an anti-SLAPP motion, arguing that Powell, as a public official, needed to prove actual malice, which he could not. The trial court denied Vericker's motion.Vericker then sought a writ of certiorari from the Third District Court of Appeal to review the denial of his anti-SLAPP motion. The Third District held that certiorari was not appropriate for reviewing such orders, aligning with the Fourth District's position that public policy favors interlocutory review through rule amendments rather than expanding certiorari jurisdiction. The Third District certified conflict with the Second District's decisions in Gundel, Baird, and Davis, which had allowed certiorari review for anti-SLAPP motions.The Supreme Court of Florida reviewed the case and held that denials of anti-SLAPP motions do not constitute irreparable harm sufficient to support certiorari relief. The court emphasized that the Anti-SLAPP statute does not provide immunity from suit but rather aims for the expeditious resolution of meritless, speech-targeted lawsuits. To align with legislative intent, the court amended Florida Rule of Appellate Procedure 9.130(a)(3) to allow interlocutory review of nonfinal orders denying anti-SLAPP motions. The court approved the Third District's decision and disapproved the Second District's conflicting decisions. View "Vericker v. Powell" on Justia Law
Mayfield v. Secretary, Florida Department of State
Debbie Mayfield, a former member of the Florida House of Representatives and Florida Senate, sought to run in a special election for Senate District 19 after the incumbent announced his resignation. Mayfield submitted the necessary paperwork to qualify for the ballot, but the Secretary of State and Director of the Division of Elections refused to place her on the ballot, citing a constitutional provision on term limits.The Circuit Court did not review the case. Mayfield directly petitioned the Supreme Court of Florida for writs of mandamus and quo warranto, arguing that the Secretary misinterpreted his authority and failed to fulfill his statutory duty.The Supreme Court of Florida reviewed the case and granted Mayfield's petition for mandamus relief. The court held that Mayfield had a clear legal right to appear on the ballot, as she had met all statutory requirements for qualification. The court found that the Secretary's role in reviewing candidate qualifications is ministerial and does not include the authority to assess a candidate's constitutional eligibility. The court also rejected the Secretary's interpretation of the term-limits provision, concluding that Mayfield's break in service meant she had not served more than eight consecutive years in the Senate. The court ordered the Secretary to place Mayfield on the ballot by a specified deadline and denied the petition for quo warranto as moot. View "Mayfield v. Secretary, Florida Department of State" on Justia Law