Justia Florida Supreme Court Opinion Summaries

The Supreme Court quashed the decision of the Fifth Circuit Court of Appeal expressly declaring valid Fla. Stat. 775.082(10), holding that subsection (10) violates the Sixth Amendment to the United States Constitution.In the decision on review, the Fifth District expressly declared subsection (10) valid in the context of rejecting Defendant’s argument that her state prison sentence violated the Sixth Amendment because the jury did not find that she presented a danger to the public under section 775.082(10). Section 775.082(1) requires that a qualifying offender whose sentencing scoresheet totals twenty-two points or fewer be sentenced to a nonstate prison sanction unless the trial court makes written findings that a nonstate prison sanction could present a danger to the public. The Supreme Court quashed the decision below, holding that subsection (10) violates the Sixth Amendment because it requires the court, not the jury, to find the fact of dangerousness to the public that is necessary to increase the statutory maximum nonstate prison sanction. View "Brown v. State" on Justia Law

The Supreme Court reversed certain portions of the decision of the Second District Court of Appeal holding that chapter 2000-439, section 18, Laws of Florida (the LMHS Lien Law) is invalid under the Florida Constitution, holding that the Second District should not have reached the question of whether the LMHS Lien Law violates the constitutional prohibition against the impairment of contracts under article I, section 10 because the issue was not properly before the court.Specifically, the Supreme Court held (1) the Second District correctly found that the LMHS Lien Law violates article III, section 11(a)(9) of the Florida Constitution as a special law pertaining to the “creation, enforcement, extension or impairment of liens based on private contracts”; (2) the Second District erred in addressing the contract-impairment issue because the Attorney General was not served with proper notice as to that issue under Fla. R. Civ. P. 1.071; and (3) a discussion of statutory damages was unnecessary in light of the determination that the LMHS Lien Law cannot be enforced due to its unconstitutionality. View "Lee Memorial Health System v. Progressive Select Insurance Co." on Justia Law

The Supreme court affirmed the circuit court’s order granting in part and denying in part Appellant’s motion for DNA testing under Fla. R. Crim. P. 3.853, holding that none of Appellant’s claims on appeal had merit.After a retrial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed on direct appeal. Appellant later filed his motion for DNA testing of evidence pursuant to Rule 3.853. After an evidentiary hearing, the circuit court granted the motion in part and denied it in part. Appellant appealed the circuit court’s partial denial of his Rule 3.853 motion. The Supreme Court affirmed, holding (1) the circuit court did not err in adopting the State’s reasoning and conclusions as to Appellant’s motion in its order; and (2) the partial denial of Appellant’s motion did not violate his Fifth, Eighth, or Fourteenth Amendment rights. View "Gosciminski v. State" on Justia Law

The Supreme Court agreed with the Fifth District Court of Appeal’s conclusion that Appellant presented no basis for declaring Florida’s hazing statute, Fla. Stat. 1006.63, unconstitutional, thus affirming Appellant’s convictions of manslaughter, felony hazing resulting in death, and two counts of misdemeanor hazing.Defendant was convicted in connection with the activities of the Florida A&M University’s marching band. On appeal, the Fifth District affirmed Defendant’s convictions, rejected his arguments challenging the constitutionality of section 1006.63, and expressly declared that the hazing statute was valid. The Supreme Court affirmed, holding that the hazing statute is neither unconstitutionally overbroad nor void for vagueness. View "Martin v. State" on Justia Law

The Supreme Court quashed the decision of the First District Court of Appeal holding that it was appropriate for an appellate court to review the entire evidentiary record to determine whether multiple convictions violate double jeopardy, holding that, consistent with State v. Shelley, 176 So. 3d 914 (Fla. 2015), to determine whether multiple convictions of solicitation of a minor, unlawful use of a two-way communications device, and traveling after solicitation of a minor are based upon the same conduct for purposes of double jeopardy, the reviewing court should consider only the charging document.Defendant moved to dismiss the charges against him, arguing that they violated double jeopardy because the elements of solicitation of a minor and unlawful use of a two-way communications device were subsumed within the elements of traveling after solicitation. The trial court denied the motion, and Defendant was convicted of all three counts. The First District affirmed after examining the entire record, concluding that there was no double jeopardy violation. The Supreme Court reversed, holding that the reviewing court should have considered only the charging document in determining whether Defendant’s convictions were based upon the same conduct for purposes of double jeopardy. View "Lee v. State" on Justia Law

The Supreme Court quashed the decision of the Fourth District Court of Appeal affirming the denial of Defendant’s motion to suppress and remanded this case to the district court with instructions that the case be remanded for a new trial without introducing portions of statements made after Defendant unequivocally invoked his right to silence, holding that the statements were produced as a result of a Miranda violation, and the error was not harmless.Defendant, who was convicted of first-degree murder and attempted first-degree murder, appealed the denial of his motion to suppress his confession on the basis that detectives had violated his right against self-incrimination and right to counsel. The Fourth District affirmed. The Supreme Court quashed the Fourth District’s decision, holding (1) a detective’s statements after Defendant unequivocally invoked his right to silence constituted interrogation; (2) the State was unable to meet its burden of demonstrating that Defendant’s subsequent Miranda waiver was voluntarily made; and (3) therefore, the trial court erred in admitting Defendant’s confession. View "Shelly v. State" on Justia Law

In this case concerning the vacancies created by the mandatory retirements of certain justices, the Supreme Court held that the phrase “within thirty days from the occurrence of a vacancy” in Fla. Const. art. V, 11(c) requires the Judicial Nominating Commission (JNC) to make its nominations no later than thirty days after the occurrence of a vacancy and does not prohibit the JNC from acting before a vacancy occurs.On October 15, 2018, the Supreme Court issued an order holding that, assuming that Justices Pariente, Lewis, and Quince finish their terms, the vacancies created by the justices’ mandatory retirements would occur outside Governor Scott’s term in office. The Court directed the JNC to submit its nominations by November 10, 2018. The Court then further clarified its holding with this opinion and recognized that there was no impediment to the JNC reopening its application period for the vacancies at issue in this case. The Court denied any additional relief. View "League of Women Voters of Florida v. Scott" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant’s successive motion for postconviction relief under Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief pursuant to Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), nor was he entitled to relief on his other claims.Appellant was convicted of the 1992 first-degree murder of his wife. The jury recommended a death sentence by a vote of seven to five. The trial court imposed a sentence of death. Appellant later filed a successive motion to vacate his death sentence in light of Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst. The circuit court summarily denied the motion. The Supreme Court affirmed, holding that because Appellant’s sentence became final prior to Ring v. Arizona, 536 U.S. 584 (2002), Appellant was not entitled to Hurst relief. View "Spencer v. State" on Justia Law

The Supreme Court approved the decision of the First District Court of Appeal affirming the trial court’s denial of Defendant’s motion to vacate his 1000-year sentences with parole eligibility pursuant to Fla. R. Crim. P. 3.850, holding that Defendant’s sentences did not violate the categorical rule of Graham v. Florida, 560 U.S. 48 (2010).Defendant committed nonhomicide crimes at age seventeen and received concurrent sentences of 1000 years. The Parole Commission, after eleven review hearings, calculated a presumptive parole release date of 2352. After the United States Supreme Court decided Graham and Miller v. Alabama, 567 U.S. 460 (2012), Defendant filed a motion to vacate his sentences pursuant to Fla. R. Crim. P. 3.850, arguing that his sentences violated the Eighth Amendment as delineated in Graham. The trial court denied the motion, and the First District Court of Appeal affirmed. The Supreme Court affirmed, holding that Defendant was not entitled to resentencing under chapter 2014,200, Laws of Florida. View "Franklin v. State" on Justia Law

The Supreme Court held that juvenile offenders’ sentences of life with the possibility of parole after twenty-five years do not violate the Eighth Amendment of the United States Constitution, as delineated by the United States Supreme Court in Graham v. Florida, 460 U.S. 48 (2010), Miller v. Alabama, 467 U.S. 460 (2012), and related cases, and therefore, such juvenile offenders are not entitled to resentencing under Fla. Stat. 921.1402.Appellee was convicted of first-degree premeditated murder and related crimes he committed when he was sixteen years old. Appellee was sentenced to life imprisonment with the possibility of parole after twenty-five years for the murder. Appellee later filed a motion for postconviction relief asserting that he was entitled to relief under Miller. The trial court summarily denied the motion, determining that Miller was inapplicable because Appellee had the opportunity for release on parole. The Fourth District Court of Appeal reversed, concluding that resentencing was required. The Supreme Court quashed the Fourth District’s opinion, holding that juvenile offenders’ sentences of life with the possibility of parole after twenty-five years do no violate Graham’s requirement that juvenile have a meaningful opportunity to receive parole. View "State v. Michel" on Justia Law