Justia Florida Supreme Court Opinion Summaries

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

After a jury trial, Appellant was convicted of first-degree murder, armed robbery, armed burglary of a conveyance, and possession of a firearm by a convicted felon. Appellant was sentenced to death. The conviction and sentence were affirmed on direct appeal. Defendant later filed a motion under Fla. R. Crim. P. 3.851 to vacate his conviction of first-degree murder and sentence of death. After an evidentiary hearing on certain of the claims raised in the motion, the circuit court denied postconviction relief. Appellant filed a notice of appeal and then filed a petition for writ of habeas corpus, contending that his appellate counsel had provided ineffective assistance. The Supreme Court affirmed the order of the circuit court denying postconviction relief and denied the petition for writ of habeas corpus, holding that none of Appellant’s claims warranted relief. View "Hayward v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder. The trial court sentenced Appellant to death. The Supreme court affirmed Appellant’s conviction and sentence of death. Appellant later filed an amended motion to vacate judgment of conviction and sentences pursuant to Fla. R. Crim. P. 3.851. After an evidentiary hearing, the circuit court denied the postconviction motion. The Supreme Court affirmed, holding (1) Appellant was not denied the effective assistance of trial counsel; and (2) Appellant failed to establish that that he was denied access to records that related to a colorable claim. View "Twilegar v. State" on Justia Law

Appellant, an intellectually disabled man, was charged with sexual battery and, in 2004, was involuntarily admitted to nonsecure residential services under Fla. Stat. 393.11. In 2011, Appellant filed suit under 42 U.S.C. 1983 and 1988 in federal district court against the Director of the Agency for Persons with Disabilities, seeking a declaratory judgment that the state’s statutory scheme for involuntarily admitting intellectually disabled persons to residential services violates the due process clause of the Fourteenth Amendment because it does not provide people who have been involuntarily admitted to nonsecure residential services with periodic review of their continued confinement by someone with authority to release them. The district court granted the Agency’s motion for summary judgment, concluding that section 393.11 is constitutional. The Eleventh Circuit Court of Appeal certified questions of law to the Supreme Court concerning the issue. The Supreme Court answered (1) “support plan” review under section 393.0651 does not require the Agency to consider the propriety of a continued involuntary admission to residential services order entered under section 393.11; and (2) the Agency is not statutorily required to petition the circuit court for the release from an involuntary admission order in cases where the Agency determines that the circumstances that led to the initial admission have changed. View "J.R. v. Palmer" on Justia Law

After a retrial, Defendant was convicted of two counts of first-degree murder. The trial court sentenced Defendant to death for both murders. The Supreme Court affirmed the convictions and sentences on direct appeal. Defendant subsequently filed a seven-claim motion to vacate judgment of conditions and sentences and later amended his motion to add two additional claims. After an evidentiary hearing on some of the claims, the postconviction court denied all of Defendant’s claims. The Supreme Court affirmed the denial of postconviction relief and also denied Defendant’s petition for habeas corpus relief, holding (1) the postconviction court properly denied Defendant’s claims of ineffective assistance of counsel; (2) the postconviction court did not err in denying Defendant’s claim of newly discovered evidence; (3) Defendant waived his Brady claim; and (4) Defendant’s appellate counsel did not perform ineffectively. View "Brooks v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder. Appellant was sentenced to life in prison without the possibility of parole for one murder and to death for the second murder. The Supreme Court affirmed Appellant’s convictions and sentences, holding (1) the evidence was sufficient to support both of Appellant’s first-degree murder convictions; (2) the trial court did not err in its findings with respect to aggravating and mitigating circumstances; (3) the death penalty was proportionate in this case; and (4) Appellant’s claim that his death sentence was unconstitutional based on Ring v. Arizona was without merit under established Florida precedent. View "Hobart v. State" on Justia Law