Justia Florida Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Court affirmed Defendant's conviction of first-degree murder and his corresponding death sentence, as well as Defendant's conviction for conspiracy to commit murder, holding that Defendant was not entitled to relief on any of his allegations of error.On appeal, Defendant raised numerous challenges to his convictions and death sentences. The Supreme Court affirmed the judgment in its entirety, holding (1) there was no merit to Defendant's arguments regarding the guilt phase of his trial; and (2) Defendant's claims regarding the penalty phase of his trial were also without merit. View "Sievers v. State" on Justia Law

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The Supreme Court approved of the decision of the First District Court of Appeal affirming Defendant's conviction for sexual battery in violation of Fla. Stat. 794.011(5)(b), holding that subsection 5(b) is not facially unconstitutional because it does not remove the State's burden to prove the defendant's general intent to engage in the act that constitutes the offense under the statute.On appeal, Defendant argued that subsection 5(b) was facially unconstitutional or must be read to include a requirement that the State prove that a criminal defendant knew or should have known the victim did not consent to sexual intercourse. The First District affirmed, disagreeing with Defendant that section 794.011(5)(b) was unconstitutional because it does not require the State to prove a defendant's mens rea. The Supreme Court affirmed, holding that the Legislature's reach did not approach the extent of its constitutional grasp where the statute makes sexual battery a crime of general intent not a strict liability offense. View "Statler v. State" on Justia Law

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The Supreme Court reversed the judgment of the postconviction court partially granting Defendant's motion to vacate his first-degree murder convictions and sentences of death pursuant to Fla. R. Crim. P. 3.851, holding that the postconviction court erred in granting a new penalty phase.Defendant pleaded guilty to two counts of first-degree murder and one count of attempted first-degree murder. After waiving a penalty-phase jury, Defendant was sentenced to death. Defendant later filed a postconviction motion under Fla. R. Crim. P. 3.851. The postconviction court summarily denied Defendant's four purely legal claims but granted a new penalty phase, ruling that counsel was deficient in investigating and presenting mitigating evidence, which prejudiced Defendant. The Supreme Court reversed, holding that Defendant failed to establish deficient performance in any respect. View "State v. Mullens" on Justia Law

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The Supreme Court affirmed the decision of the postconviction court denying Defendant's motion to vacate his convictions and sentences, including three convictions for first-degree murder and three sentences of death, holding that Defendant was entitled to neither postconviction relief nor a writ of habeas corpus.In 2014, Defendant pleaded guilty to murdering his girlfriend and her two children. The trial court sentenced Defendant to death for each murder. Defendant later filed a motion for postconviction relief, which the trial court denied. Defendant appealed the court's decision and filed a petition for a writ of habeas corpus, raising two claims. The Supreme Court denied relief, holding (1) as to Defendant's petition for postconviction relief, Defendant failed to demonstrate error, deficiency, or prejudice as to any of his claims; and (2) as to Defendant's habeas corpus petition, Defendant was not entitled to relief on his claims. View "Covington v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder and his sentence of death, holding that Defendant was not entitled to relief on his allegations of error.Defendant pleaded guilty to first-degree premeditated murder, after which the trial court sentenced him to death. Defendant challenged his sentence on appeal, arguing that the trial court failed to ensure that all available mitigation was developed and presented and failed to determine beyond a reasonable doubt that the aggravating factors were sufficient to justify death and outweighed the mitigating circumstances. The Supreme Court affirmed, holding (1) there was no fundamental error in the trial court's rulings regarding mitigation; (2) Defendant knowingly and voluntarily entered his plea, was made aware of the consequences, and was apprised of the constitutional rights he was waiving; and (3) Defendant's remaining claim was unavailing. View "Fletcher v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying the guilt-phase claims Kim Jackson raised in his motion for postconviction relief filed under Fla. R. Crim. P. 3.851 and denied Jackson's petition for a writ of habeas corpus, holding that Jackson was not entitled to relief.After a jury trial, Jackson was found guilty of first-degree murder and sentenced to death. The Supreme Court affirmed. Jackson subsequently filed a postcondition motion raising more than twenty claims for relief. The circuit court vacated Jackson's death sentence under Hurst v. State, 202 So. 3d 40 (Fla. 2016), and otherwise affirmed. The Supreme Court affirmed and denied habeas corpus relief, holding (1) a due process claim for preindictment delay requires a showing of substantial prejudice to the defendant and bad faith on the part of the State; (2) as to two of Jackson's claims of ineffective assistance of counsel this Court assumed deficient performance but found no prejudice; and (3) Jackson was not entitled to a writ of habeas corpus. View "Jackson v. State" on Justia Law

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The Supreme Court approved the holding of the court of appeal that Fla. Const. art. I, 14 does not prohibit the trial court the discretion at first appearance, upon a finding of probable cause that the defendant committed a crime punishable by capital punishment or life imprisonment, to defer ruling on bail and to detain the defendant for a reasonable time to conduct a "full" Arthur bond hearing, holding that there was no error.Defendant was arraigned on one count of robbery using a firearm or deadly weapon. After a hearing held pursuant to State v. Arthur, 390 So. 2d 717 (Fla. 1980) the trial court concluded that the evidence was sufficient to convict Defendant of unarmed robbery and granted him pretrial release and bail in the amount of $25,000. On appeal, Defendant argued that the first sentence of article 1, section 14 creates a two-step procedure. The court of appeals rejected this argument. The Supreme Court affirmed, holding that article I, section 14 does not prohibit a trial court from detaining a defendant beyond first appearance without setting release unless the court has made a preliminary finding that the proof of guilt is evident or the presumption is great. View "Thourtman v. Junior" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Billy Sheppard Jr.'s motion to vacate his conviction of first-degree murder and denied Sheppard's petition for a writ of habeas corpus, holding that the circuit court properly denied postconviction relief for all guilt claims and that Sheppard failed to establish that he was entitled to habeas corpus relief.Sheppard was convicted of first-degree murder and sentenced to death. Sheppard later filed a motion to vacate his conviction and sentence under Fla. R. Crim. P. 3.851. The circuit court granted a new penalty phase but denied Sheppard's claims as to the guilt phase of his trial. Sheppard appealed, raising claims relevant to the guilt phase, and filed a petition for writ of habeas corpus raising two claims of ineffective assistance of counsel. The Supreme Court affirmed the circuit court's order and denied Sheppard's petition for writ of habeas corpus, holding that Sheppard was not entitled to relief on any of his claims. View "Sheppard v. State" on Justia Law

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The Supreme Court affirmed Defendant's two first-degree murder convictions and two corresponding sentences of death, holding that Defendant was not entitled to relief on his allegations of error.After a trial, a jury found Defendant guilty of two counts of first-degree murder with a firearm. The jury rendered unanimous verdicts recommending a penalty of death on both murder counts, determining that the aggravating factors outweighed the mitigating circumstances. In this direct appeal, Defendant raised fifteen claims, including several challenges to the trial court's evidentiary rulings and to Florida's death penalty scheme. The Supreme Court affirmed Defendant's convictions for first-degree murder and his sentences of death, holding that Defendant failed to establish prejudicial error in any respect. View "Joseph v. State" on Justia Law

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The Supreme Court affirmed the judgment of the trial court summarily denying Appellant's sixth successive motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, holding that the trial court did not err in summarily denying Appellant's postconviction motion.Appellant was convicted of first-degree murder, sexual battery, and burglary. The trial judge sentenced Appellant to death. In his sixth successive postconviction motion Appellant asserted two claims, including a claim under Brady v. Maryland, 373 U.S. 83 (1963). The trial court rejected both claims. The Supreme Court affirmed, holding that the trial court did not err in summarily denying Appellant's sixth postconviction motion. View "Booker v. State" on Justia Law