Justia Florida Supreme Court Opinion Summaries

When Defendant was fourteen years old he pleaded guilty to attempted first-degree murder, attempted armed robbery, and aggravated battery. The trial court adjudicated Defendant guilty as charged and imposed prison terms of seventy years for the attempted murder conviction and twenty-five years for the attempted armed robbery conviction. Defendant appealed and filed a motion pursuant to Fla. R. Crim. P. 3.800(b)(2), arguing that, under the rationale of Graham v. Florida, his seventy-year prison sentence constituted cruel and unusual punishment. The trial court denied the requested relief. The First District Court of Appeal affirmed, holding that Graham did not apply in Defendant’s case because he did not face a life sentence without the possibility of parole. The Supreme Court quashed the First District’s decision to the extent it affirmed the seventy-year prison sentence and remanded to Defendant’s sentencing court, holding that Defendant’s seventy-year prison sentence did not provide a meaningful opportunity for future release, and therefore, the sentence was unconstitutional in light of Graham. View "Gridine v. State" on Justia Law

Defendant was convicted of the first-degree murder of his father and sentenced to death. The Supreme Court affirmed the conviction and sentence, holding (1) the evidence supported the finding that the murder was committed in a cold, calculated, and premeditated manner and that the murder was motivated by financial gain; (2) the trial court erred in finding that the murder was especially heinous, atrocious, or cruel, but the error was harmless; (3) because Ring v. Arizona did not apply in this case, Defendant’s argument that Florida’s sentencing scheme is unconstitutional under Ring was denied; (4) the death sentence in this case was proportionate; and (5) the jury had competent, substantial evidence on which to find Defendant guilty of first-degree murder. View "Campbell v. State" on Justia Law

Defendant was convicted of first-degree murder, attempted first-degree murder, burglary of a dwelling with a battery therein, and attempted robbery with a deadly weapon. Defendant was sentenced to death for the murder. The Supreme Court affirmed Defendant’s convictions and sentences on appeal. Defendant later filed a motion to vacate judgment of convictions and sentences, alleging several claims of error. The postconviction court denied all claims. Defendant appealed the denial of his postconviction motion and also filed a petition for writ of habeas corpus, presenting two habeas claims. The Supreme Court affirmed the postconviction court’s order denying postconviction relief on all claims and denied habeas relief, holding that the postconviction court did not err in its judgment and that Defendant’s habeas claims were without merit. View "Miller v. State" on Justia Law

After a jury trial, Emilia Carr was found guilty of first-degree murder and kidnapping. The trial court sentenced Carr to death, concluding that the aggravating circumstances outweighed the mitigating circumstances. The Supreme Court affirmed Carr’s conviction for first-degree murder and her sentence of death, holding (1) the trial court’s evidentiary rulings as to the admissibility of certain documents were proper; (2) the trial court did not err by denying Carr’s motions to continue; (3) the trial court did not err by overruling Carr’s objections to certain prosecutorial comments during the penalty phase; (4) the trial court did not err in its treatment of the mitigating evidence; (5) the trial court did not err in finding the cold, calculated, and premeditated aggravator and the heinous, atrocious, or cruel aggravator; (6) the death sentence was proportionate; and (7) there was sufficient evidence to support Carr’s first-degree murder conviction. View "Carr v. State" on Justia Law

In this “Craigslist killer case,” Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not violate the Supreme Court’s holding in Muhammad v. State by not calling its own witnesses that had knowledge of mitigation after Defendant decided to waive the presentation of mitigating circumstances; (2) Defendant failed to provide a good-faith basis for suggesting that the Court recede from controlling precedent established in Hamblen v. State, which subjects a trial court’s judgment about whether to call its own mitigation witnesses or appoint special mitigation counsel to an abuse of discretion standard of review; (3) the trial court did not violate Ring v. Arizona in sentencing Defendant to death; (4) there was sufficient evidence to support the conviction; and (5) Defendant’s death sentence was proportionate. View "Sparre v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder and burglary of a dwelling with a firearm. The trial court sentenced Defendant to death for the two murders. The Supreme Court affirmed Defendant’s convictions and death sentences, holding (1) the trial court did not commit error in its evidentiary rulings; (2) no fundamental error occurred in the trial court’s placement of certain restrictions on Defendant’s presentation of his case; (3) the prosecutor did not improperly comment on Defendant’s guilt in front of the jury; (4) the trial court did not err in finding certain aggravating circumstances; (5) there was sufficient evidence to support the convictions; (6) the death sentences were proportionate; and (7) the trial court did not violate the attorney-client privilege by appointing Defendant’s standby counsel and investigators to present mitigation. The Court also prospectively modified the principles and procedures articulated in Muhammad v. State to the limited extent that trial courts should utilize an independent, special counsel, rather than standby counsel, to present mitigation evidence even when the defendant waives mitigation - as was done in this case. View "Marquardt v. State" on Justia Law

After a jury trial, Appellant was convicted of the murder of a seventy-year-old woman. Appellant was sentenced to death. The Supreme Court affirmed on appeal. Appellant subsequently filed a motion to vacate his conviction and sentence pursuant to Fla. R. Crim. P. 3.851, asserting, inter alia, that he received ineffective assistance of trial counsel. The postconviction court denied all claims. Appellant appealed the denial of his postconviction motion and also petitioned for a writ of habeas corpus. The Supreme Court affirmed the denial of Appellant’s postconviction claims and denied his petition for a writ of habeas corpus, holding (1) the postconviction court did not err in determining that Appellant failed to demonstrate prejudice by any purported failure to trial counsel; and (2) the majority of Appellant’s claims were not cognizable in a petition for habeas relief, and the remainder of his claims were without merit. View "Zommer v. State" on Justia Law

Appellant was found guilty of first-degree murder and three counts of sexual battery with the use of a deadly weapon or physical force, among other crimes. Appellant was sentenced to death. Appellant later filed a motion for postconviction relief pursuant to Fla. R. Crim. P. 3.850 and 3.851, alleging a claim of newly discovered evidence. Specifically, Appellant alleged that he was not the shooter and that his codefendant was the shooter. The trial court denied relief, determining that the newly discovered evidence was not credible and would not have changed the outcome of the trial. The Supreme Court affirmed. Appellant then filed a successive postconviction motion pursuant to rule 3.851, asserting claims of newly discovered evidence and ineffective assistance of postconviction counsel. The trial court summarily denied the motion. The Supreme Court affirmed, holding (1) the record conclusively showed that Appellant was not entitled to relief on his claim of newly discovered evidence; and (2) Appellant’s ineffective assistance of postconviction counsel claim was not cognizable in a rule 3.851 motion. View "Kormondy v. State" on Justia Law

Appellant was convicted of two counts of first-degree murder, two counts of kinapping, and two counts of robbery. The trial court imposed two sentences of death for each murder. The Supreme Court affirmed on appeal. Appellant later filed a motion for postconviction relief, raising twelve issues. After an evidentiary hearing conducted on two of Appellant’s claims, the postconviction court denied relief. The Supreme Court affirmed, holding that the postconviction court did not err in denying Appellant’s claims that trial counsel was ineffective during the guilt phase, during the penalty phase, and during jury selection. View "Wade v. State" on Justia Law

After a jury trial, Norman McKenzie was convicted of two counts of first-degree murder. The trial court sentenced McKenzie to death for the murders. The Supreme Court affirmed the convictions and sentences. McKenzie later filed a motion to vacate the convictions and sentences pursuant to Fla. R. Crim. P. 3.851, asserting four claims. The postconviction court summarily denied the motion without an evidentiary hearing. McKenzie appealed and also petitioned for a writ of habeas corpus. The Supreme Court affirmed, holding (1) McKenzie’s ineffective assistance of counsel claim, in which he presented several issues arising from his decision to represent himself during his capital criminal proceeding, was properly denied; (2) McKenzie was not entitled to a second proportionality review at the postconviction appellate stage for evidence he chose not to present during his capital trial; and (3) McKenzie was not entitled to relief on his claim that because he was mentally ill, to execute him would be unconstitutional. View "McKenzie v. State" on Justia Law