Justia Florida Supreme Court Opinion Summaries

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

The Communications Services Tax (CST) imposed a 6.8 percent tax rate on cable service and a 10.8 percent tax rate on satellite service. DIRECTV, Inc. and Echostar, LLC filed suit seeking a declaratory judgment holding the sales tax provision in the CST unconstitutional, a permanent injunction against enforcement of the provision, and a refund of taxes paid pursuant to the provision. The trial court found that the CST does not violate the Commerce Clause. The First District Court of Appeal reversed, concluding that the CST is invalid because it favors communications that use local infrastructure and therefore has a discriminatory effect on interstate commerce. The Supreme Court reversed, holding that the CST is not discriminatory in either its purpose or its effect and therefore does not violate the dormant Commerce Clause. View "Florida Department of Revenue v. DirecTV, Inc." on Justia Law

After a jury trial, Appellant was found guilty of premeditated first-degree murder and of attempted second-degree murder. The trial court, following the jury’s recommendation, sentenced Appellant to death. The Supreme Court affirmed Appellant’s conviction and death sentence on direct appeal. Appellant then filed a motion for postconviction relief under Fla. R. Crim. P. 3.851, raising multiple claims of ineffective assistance of counsel during the guilt phase and claiming that he was entitled to relief after the United States Supreme Court issued its decision in Hurst v. Florida. The trial court denied the motion. The Supreme Court affirmed the denial of the guilt phase claims but vacated the death sentence and remanded for a new penalty phase pursuant to Hurst v. State, holding that where the jury recommended death by a vote of ten to ten, the error in Appellant’s sentencing was not harmless beyond a reasonable doubt. View "McMillian v. State" on Justia Law