Justia Florida Supreme Court Opinion Summaries

Defendant pled guilty to first-degree murder and robbery with a weapon. The trial court sentenced Defendant to death. The Supreme Court affirmed the convictions and sentences on appeal. Defendant subsequently filed an amended Fla. R. Crim. P. 3.851 motion raising four claims alleging ineffective assistance of counsel. The trial court denied all claims after an evidentiary hearing. The Supreme Court affirmed the postconviction court’s denial of relief under Rule 3.851, holding that Defendant failed to demonstrate that counsel were ineffective at either the guilt or penalty phases of his trial. View "Guardado v. State" on Justia Law

Appellant was convicted of four counts of first-degree murder and sentenced to death for each murder. After Governor Scott signed the death warrant Appellant filed a third successive motion for postconviction relief, claiming, inter alia, that Florida’s death penalty statute is unconstitutional. Appellant also filed extensive public records requests with several entities. Appellant was provided with some, but not all, of the requested records. The circuit court summarily denied Appellant’s third successive postconviction motion. Appellant subsequently filed a fourth successive postconviction petition, asserting, inter alia, that Florida’s lethal injection protocol is unconstitutional because of the use of midazolam. The circuit court denied Appellant’s fourth successive motion for postconviction relief. The Supreme Court affirmed the denial of Appellant’s third and fourth successive motions for postconviction relief, as well as the circuit court orders sustaining the objections to the public records requests, holding (1) Appellant’s challenge to the use of midazolam failed; (2) Appellant’s public records challenges were without merit; and (3) Appellant was not entitled to relief on the remainder of his claims. View "Correll v. State" on Justia Law

In 2004, Defendant was convicted of first-degree murder. The trial court entered an order sentencing Defendant to death. The Supreme Court affirmed on appeal. Defendant filed a motion for postconviction relief under Fla. R. Crim. P. 3.851 alleging ineffective assistance of counsel and a Brady/Giglio claim. The court denied Defendant’s motion to vacate his conviction and sentence in its entirety. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus, alleging ineffective assistance of counsel. The Supreme Court (1) affirmed the order denying postconviction relief, holding that the postconviction court did not err in its rulings; and (2) denied Defendant’s petition for a writ of habeas corpus, holding that Defendant failed to establish that he received ineffective assistance of counsel. View "Hernandez v. State" on Justia Law

In 2005, Defendant was convicted of first-degree murder, attempted armed robbery, and grand theft of a motor vehicle. The trial court sentenced Defendant to death for the murder conviction. The Supreme Court affirmed on appeal. In 2009, Defendant filed a second amended motion for postconviction relief, alleging several claims. The postconviction court denied Defendant’s motion to the extent it requested a new guilt phase but granted the motion to the extent that it requested a new penalty phase. Defendant appealed and, in addition, filed a petition for a writ of habeas corpus, asserting four claims. The Supreme Court affirmed the postconviction court’s order that denied Defendant’s request for a new guilt phase trial and denied his petition for a writ of habeas corpus, holding (1) the postconviction court did not err in its rulings; and (2) Defendant was not entitled to relief on his habeas corpus claims. View "Blake v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder and related crimes. The trial court sentenced Defendant to death for the murders. Defendant later filed a motion to vacate his conviction and sentence. The circuit court treated Defendant’s filing as an initial motion pursuant to Fla. R. Crim. P. 3.851 and summarily denied all of his claims for postconviction relief. Defendant appealed the denial of his motion and, in addition, petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court (1) affirmed the circuit court’s summary denial of relief, holding that while Defendant’s claims of trial court error were insufficiently pleaded and without merit, it was necessary to address the unusual procedure employed for jury selection in Defendant’s trial; and (2) denied the petition for writ of habeas corpus, holding that appellate counsel was not ineffective during Defendant’s direct appeal. View "Hojan v. State" on Justia Law

After an adjudicatory hearing, the trial court entered judgment terminating Mother’s parental rights to her child. Mother appealed, alleging ten claims of ineffective assistance of counsel regarding her counsel’s performance in the termination of parental rights (TPR) proceedings. The district court of appeal applied the Washington v. Strickland standard to Mother’s ineffective assistance of counsel claims and affirmed the order terminating Mother’s parental rights. The district court subsequently certified two questions regarding the right to effective counsel in TPR proceedings and vindication of that right. In its opinion, the Supreme Court established the appropriate standard for determining whether counsel provided constitutionally ineffective assistance in termination of parental rights proceedings and directing the development of rules providing the procedure for vindicating a parent’s constitutional right to the effective assistance of counsel in TPR proceedings. The Court then affirmed in this case, holding that Mother failed to present any basis for setting aside the order terminating her parental rights. View "J.B. v. Fla. Dep’t of Children & Families" on Justia Law

A trial court found that the Legislature’s 2012 congressional redistricting plan was drawn in violation of the Florida Constitutional’s prohibition on partisan intent because Florida’s twenty-seven congressional districts were apportioned in such a way as to favor the Republican Party and incumbent lawmakers. The Supreme Court (1) affirmed the trial court’s finding that the Legislature’s enacted map was tainted by unconstitutional intent; but (2) reversed the trial court’s order upholding the Legislature’s remedial redistricting plan, as the court failed to give proper legal effect to its determination that the Fair Districts Amendment was violated. Remanded to the trial court with directions that it require the Legislature to redraw certain congressional districts pursuant to the guidelines set forth in this opinion. View "League of Women Voters of Fla. v. Detzner" on Justia Law

Appellant was convicted of the 2002 first-degree murders of three individuals. The trial court sentenced Defendant to death for two of the murders and to life imprisonment for the third murder. The Supreme Court affirmed the convictions and sentences. This appeal concerned Appellant’s initial postconviction motion in which he asserted that his trial counsel was ineffective in failing to call experts to testify as to mental health mitigation at trial or at the subsequent Spencer hearing and in failing to move for a change of venue. The circuit court denied postconviction relief. The Supreme Court affirmed, holding (1) Appellant failed to establish ineffective assistance of counsel as to his first claim; and (2) the circuit court correctly denied Appellant’s second claim of ineffective assistance of counsel. View "Carter v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, two counts of grand theft of a motor vehicle, home-invasion robbery, two counts of burglary, and escape. The trial court imposed a sentence of death for the murder. The Supreme Court affirmed the convictions and death sentence, holding, (1) the trial court did not err in denying Defendant’s motion to sever certain of the charges; (2) the trial court did not err in denying Defendant’s motion to suppress his post-arrest statement; (3) any references that were made to defendant’s incarceration at the time of his escape were not so prejudicial as to vitiate the entire trial; (4) the prosecutor did not commit misconduct during guilt-phase closing statements or penalty-phase closing arguments; (5) the sentencing order was proper; (6) Defendant’s constitutional challenge to Florida’s capital sentencing scheme was without merit under established Florida precedent; and (7) the death sentence was not disproportionate in this case. View "Fletcher v. State" on Justia Law

Defendant was convicted and sentenced to death for the murders of a correctional officer and an inmate. Defendant committed the murders while attempting to escape from prison where he was serving a life sentence for a prior murder. Defendant filed a motion for postconviction relief pursuant to Fla. R. Crim. p. 3.851. The postconviction court denied relief. Defendant appealed and simultaneously petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the postconviction court’s denial of relief and denied Defendant’s petition for a writ of habeas corpus, holding (1) Defendant did not receive ineffective assistance of trial counsel during either the guilt phase or the penalty phase; (2) the postonviction court did not err in summarily denying two of Defendant’s postconviction claims; and (3) appellate counsel did not provide ineffective assistance. View "Eaglin v. State" on Justia Law