Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended a sentence of death by a vote of seven to five. The trial court followed the jury’s recommendation and imposed a sentence of death. The Supreme Court affirmed Defendant’s conviction but reversed his death sentence, holding (1) the trial court did not err in denying Defendant’s motions for mistrial during the guilt phase; (2) any error by the State in its statements during closing arguments did not rise to the level of fundamental error; (3) the evidence was sufficient to sustain a felony-murder conviction; but (4) the failure to require a unanimous verdict was not harmless in this case. Remanded to the trial court for a new penalty phase. View "Guzman v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, robbery, fleeing and eluding, and resisting arrest with violence. At the penalty phase of trial, the jury recommended death by a vote of ten to two. The trial court followed the recommendation and sentenced Defendant to death. The Supreme Court affirmed the trial court’s denial of Defendant’s guilt phase claims but reversed and remanded for a new penalty phase, holding that because the non unanimous jury did not make the findings required under Hurst v. State, the error was not harmless, and Defendant was entitled to a new penalty phase under Hurst v. Florida, as interpreted by the Supreme Court in Hurst v. State. View "Bradley v. State" on Justia Law

After a jury trial, Defendant was convicted of premeditated or felony murder, robbery, and sexual battery. The jury recommended the death penalty by a vote of seven to five. The trial judge followed the recommendation and sentenced Defendant to death. Defendant appealed his death sentence. The Supreme Court affirmed. Defendant later filed the instant motion for postconviction relief, presenting, inter alia, ineffective assistance of counsel. The postconviction court denied all claims. Defendant appealed the denial of his motion, raising claims of ineffective assistance of resentencing phase counsel and ineffective assistance of postconviction counsel. Defendant also petitioned for a writ of habeas corpus, alleging ineffective assistance of appellate counsel. The Supreme Court vacated Defendant’s death sentence and remanded for a new penalty phase, holding that Defendant was entitled to a new penalty phase pursuant to Hurst v. Florida, as interpreted by the Court’s decision in Hurst v. State. View "Orme v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury returned a recommendation in favor of death by a vote of eight to four. The trial court accepted the recommendation and sentenced Defendant to death. The Supreme Court affirmed the conviction and vacated the death sentence, holding (1) it cannot be concluded beyond a reasonable doubt that a Hurst v. Florida error did not contribute to Defendant’s sentence; and (2) the trial court properly denied Defendant’s motion for judgment of acquittal, and there was no error in the guilt phase of trial. Remanded for a new penalty phase. View "Deviney v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, kidnapping, and home invasion robbery. At the conclusion of the penalty phase, the jury recommended death by a vote of nine to three. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s convictions and sentences. Defendant then filed a postconviction motion pursuant to Fla. R. Crim. P. 3.851. The trial court denied all relief after an evidentiary hearing. Defendant appealed the denial of his postconviction motion and also filed a petition for a writ of habeas corpus. The Supreme Court reversed the trial court’s denial of Defendant’s claim related to the constitutionality of Florida’s death penalty scheme, vacated Defendant’s death sentence as unconstitutional under Hurst v. Florida, and denied habeas relief, holding (1) the Hurst error in Defendant’s penalty phase was harmless beyond a reasonable doubt, and Defendant was entitled to a new penalty phase; and (2) Defendant’s remaining claims were unavailing. View "Baker v. State" on Justia Law

Appellant was convicted of first-degree murder, sexual battery with a deadly weapon, and other offenses. The trial court sentenced Appellant to death for the murder conviction. The Supreme Court affirmed Appellant’s convictions but reversed his sentences, holding (1) no prejudicial error occurred during the guilt phase of Appellant’s trial; but (2) Appellant’s death sentence was not based upon factual findings by a jury of his peers, as required by the Sixth Amendment, but upon a nonunanimous jury recommendation, and the Hurst v. Florida errors that occurred during sentencing were not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Jackson v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder. The jury recommended the death sentence by a vote of ten to two. The Supreme Court affirmed the conviction and the death sentence. Thereafter, Appellant filed a motion for postconviction relief under Fla. R. Crim. P. 3.851, raising twelve claims. The trial court denied relief. The Supreme Court affirmed the postconviction court’s oder as to Appellant’s conviction but vacated the death sentence and remanded for a new penalty phase, holding (1) Appellant was not denied the effective assistance of counsel under Strickland v. Washington; but (2) in light of the nonunanimous jury recommendation to impose a death sentence, it cannot be said that the failure to require a unanimous verdict in this case was harmless. View "Hodges v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder, two counts of kidnapping, two counts of robbery, and one count of carjacking. The trial court sentenced Defendant to death for each murder and life imprisonment for each of his other convictions. The Supreme Court affirmed Defendant’s convictions and sentences. Defendant later filed an amended motion to vacate his judgment and sentences and a renewed motion for determination of intellectual disability. The postconviction court denied both motions. The Supreme Court affirmed, holding (1) the postconviction court properly determined that Defendant is not among those intellectually disabled defendants that cannot be executed; (2) with regard to every claim raised in Defendant’s amended motion to vacate his judgment and sentences, Defendant failed to demonstrate that the postconviction court erred in finding no Strickland error occurred; and (3) Defendant was not entitled to relief pursuant to Hurst v. Florida. View "Wright v. State" on Justia Law

After a jury trial, Defendant was convicted of four counts of first-degree murder, four counts of conspiracy to commit murder, two counts of manslaughter, and other crimes. The jury recommended by a vote of ten to two that Defendant be sentenced to death for one murder and also recommended a death sentence for another murder by a vote of nine to three. The trial court followed the jury’s death-sentence recommendations. The Supreme Court affirmed Defendant’s first-degree murder convictions and sentences of death on direct appeal. Defendant later filed a motion to vacate his convictions and sentences pursuant to Fla. R. Crim. P. 3.851, setting forth eight claims. The trial court denied Defendant’s Rule 3.851 motion. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the trial court’s denial of postconviction relief as to all claims except Defendant’s claim relating to the constitutionality of his penalty phase, denied habeas relief, vacated Defendant’s death sentences, and remanded for a new penalty phase, holding that Defendant’s death sentence was unconstitutional under Hurst v. Florida. View "Smith v. State" on Justia Law

Cary Michael Lambrix was convicted and sentenced to death for the 1983 first-degree murder of two victims. The Supreme Court affirmed Lambrix’s murder convictions and death sentences on direct appeal. After the Governor signed a death warrant and the execution was set, Lambrix filed both a successive motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851 and a motion for postconviction DNA testing pursuant to Fla. R. Crim. P. 3.853. The postconviction court summarily denied both of Lambrix’s motions. Lambrix appealed those orders and filed a petition for writ of habeas corpus. After the U.S. Supreme Court issued its opinion in Hurst v. Florida, the Supreme Court permitted supplemental briefing and oral argument to consider the impact of Hurst in this case. The Supreme Court ultimately affirmed the postconviction court’s denial of relief and denied Lambrix’s separate petition for habeas corpus, holding (1) Lambrix was not entitled to a new penalty phase based on Hurst v. Florida or Hurst v. State; and (2) the other grounds that Lambrix raised were devoid of merit. View "Lambrix v. State" on Justia Law