Justia Florida Supreme Court Opinion Summaries

Donte Jermaine Hall was convicted and sentenced to death for the murder of Anthony Blunt. The jury voted eight to four in favor of a death sentence for the murder of Blunt. The trial court followed the jury’s recommendation. Hall filed a motion for postconviction relief under Fla. R. Crim. P. 3.851. He appealed the denial of that motion and also petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of Hall’s postconviction guilt phase claims, denied the habeas guilt phase claims, but vacated his death sentence and remanded for a new penalty phase, holding (1) the trial court did not err in denying Hall’s ineffective assistance of trial counsel claim; (2) the trial court did not err in denying Hall’s ineffective assistance of appellate counsel claim; and (3) Hall’s death sentence violated Hurst v. Florida, 577 U.S. __ (2016), and the Hurst error was not harmless beyond a reasonable doubt. View "Hall v. State" on Justia Law

Thomas Bevel was found guilty of two counts of first-degree murder. The jury recommended the death penalty by a vote of eight to four as to the murder of Garrick Springfield and by a unanimous vote of twelve to zero as to the murder of Phillip Sims. The trial court followed the jury’s recommendations. Bevel later filed a motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, raising ten claims. The postconviction court denied relief, including Bevel’s ineffective assistance of penalty phase counsel claim. Bevel appealed and filed a petition for a writ of habeas corpus, claiming ineffective assistance of appellate counsel and arguing that he was entitled to relief under Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court denied Bevel’s habeas petition but reversed the denial of postconviction relief, vacated Bevel’s death sentences, and remanded for a new penalty phase proceeding, holding (1) Bevel was entitled to Hurst relief for his death sentence for the murder of Springfield; (2) penalty phase counsel conducted an unreasonable mitigation investigation, and because Bevel met the prejudice prong under Strickland, his death sentence for the murder of Sims must be vacated; and (3) Bevel’s remaining claims of error were unavailing. View "Bevel v. State" on Justia Law

The caps on personal injury noneconomic damages in medical negligence actions provided in Fla. Stat. 766.118 violate the Equal Protection Clause of the Florida Constitution.This case arose after complications from surgery left Appellee severely injured. After trial, Appellee’s noneconomic damages were capped by Fla. Stat. 766.118(2) and (3). The Fourth District Court of Appeal directed the trial court to reinstate the total damages award as found by the jury, concluding that section 766.118 was invalid. The Supreme Court affirmed, holding (1) the caps on noneconomic damages in sections 766.118(2) and (3) arbitrarily reduce damage awards for plaintiffs who suffer drastic injuries; and (2) there is no rational relationship between the personal injury noneconomic damage caps in section 766.118 and alleviating a purported medical malpractice insurance criss. View "North Broward Hospital District v. Kalitan" on Justia Law

The Supreme Court approved the holding of the First District Court of Appeal in City of Jacksonville v. Smith, 159 So. 3d 888 (Fla. 1st CA 2015), that the Bert J. Harris Jr., Private Property Protection Act (Act) does not apply to claims from government action that regulates property adjacent to the claimant’s property and disapproved the Second District Court of Appeal’s contrary decision in FINR II, Inc. v. Hardee County, 164 So. 3d 1260 (Fla. 2d DCA 2015).Hardee County granted FINR, Inc., which operated a neurological rehabilitation center on a parcel adjacent to property owned by a phosphate mining company, a setback on the phosphate mining company’s adjacent property. Hardee County subsequently decreased the quarter-mile setback to as little as 150 feet. FINR brought a claim under the Act seeking $38 million in damages for devaluation of its property. The trial court concluded that the Act did not apply to FINR because the quarter-mile setback change did not directly restrict or limit FINR’s property. The Second District reversed and certified conflict with Smith. The Supreme Court disapproved the decision below, holding that the setback in this case was not a property right for which FINR may state a claim under the Act. View "Hardee County v. FINR II, Inc." on Justia Law

The Supreme Court granted John Lee Hampton’s petition for a writ of habeas corpus, vacated Hampton’s sentence of death, and ordered that Hampton receive a new penalty phase proceeding in light of Hurst v. State. In addition, the Court affirmed the postconviction court’s order denying Hampton’s motion to vacate his conviction of first-degree murder and sentence of death to the extent it denied Hampton relief based upon his claim of ineffective assistance of guilt phase counsel and further affirmed the determination that Hampton was not intellectually disabled. The Court declined to address the remaining issues in Hampton’s appeal of the postconviction court’s order, which relate to penalty phase issues, due to its holding that the Hurst error during Hampton’s penalty phase proceedings was not harmless beyond a reasonable doubt. View "Hampton v. State" on Justia Law

Defendant was convicted of first-degree murder. The jury recommended the death penalty by a vote of nine to three. The Supreme Court followed the recommendation and sentenced Defendant to death. Defendant filed a motion to vacate his conviction and sentence under Fla. R. Crim. P. 3.851. The circuit court denied the motion. Defendant appealed this denial and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court vacated the death sentence and remanded for a new penalty phase, holding (1) the trial court did not err in denying Defendant’s ineffective assistance of trial counsel and appellate counsel claims; and (2) Defendant’s death sentence violated Hurst v. State, and the Hurst error was not harmless beyond a reasonable doubt. View "Altersberger v. State" on Justia Law

Appellant was convicted and sentenced to death on two counts for the first-degree premeditated murders of two police officers. The Supreme Court affirmed the convictions and sentences, holding (1) the trial court did not err in denying Appellant’s motion to strike the jury panel based on statements made by a prospective juror during jury selection; (2) the trial court did not err in admitting a redacted statement statement while he was under observation in jail, and any error in preventing the defense from presenting evidence regarding Appellant’s mental state at the time he made the statement was harmless; (3) the trial court did not err in allowing law enforcement officers to give opinions identifying Appellant’s voice and image from a dash cam videotape; (4) the trial court did not err in admitting a witness’s prior consistent statements; (5) the trial court did not err in denying Appellant’s motion for mistrial; and (6) competent, substantial evidence supported Appellant’s convictions. View "Morris v. State" on Justia Law

After a jury trial, Donald Lenneth Banks was found guilty of first-degree murder. The jury recommended the death penalty by a vote of ten to two. Following the jury’s recommendation, the trial court sentenced Banks to death. On appeal, the Supreme Court affirmed Banks’ conviction and sentence. Thereafter, Banks filed a motion under Fla. R. Crim. P. 3.851 to vacate his murder conviction and sentence of death, alleging ineffective assistance of counsel. The postconviction court denied the motion. Banks appealed the denial of his Rule 3.851 motion and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of Banks’ postconviction guilt phase claims, denied his habeas petition, but vacated his death sentence, holding (1) trial court provided effective assistance of counsel; but (2) Banks’ death sentence violated Hurst v. State, and the Hurst error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Banks v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree premeditated and felony murder. The jury recommended the death penalty by a vote of ten to two. The trial court followed the jury’s recommendation and sentenced Defendant to death. The Supreme Court affirmed the convictions but vacated the death sentence, holding (1) the trial court did not err by admitting, for purposes of impeachment, collateral crime evidence that Defendant signed a sworn statement in which he admitted to concealing a metal shank inside his pants while in jail awaiting trial for the victim’s murder; (2) the State did not improperly comment on Defendant’s right to silence; (3) the evidence was sufficient to support Defendant’s conviction; but (4) Defendant’s death sentence violated Hurst v. State, and the Hurst error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Brookins v. State" on Justia Law

Petitioner pleaded guilty to armed burglary of a dwelling, armed kidnapping, attempted first-degree murder, and sexual battery using force or a weapon. Petitioner was sentenced to six concurrent life sentences. Petitioner’s sentences were based on offenses he committed when he was seventeen years old. After the United States Supreme Court issued its decision in Graham v. Florida, the trial court set aside Petitioner’s life sentences and, after an evidentiary hearing, resentenced Petitioner to 100 years in prison for the first count and forty years on each remaining count, to run concurrently. The Fifth District Court of Appeal affirmed Petitioner’s sentence, concluding that Graham does not apply to term-of-years sentences. The Supreme Court quashed the decision of the Fifth District, holding that Petitioner’s 100-year sentence violates Graham and the Supreme Court’s decisions in Henry v. State and Kelsey v. State. Remanded. View "Johnson v. State" on Justia Law