Justia Florida Supreme Court Opinion Summaries

Appellant was convicted of first-degree murder, attempted armed robbery, and grand theft of a motor vehicle. The trial court imposed a sentence of death for the murder conviction. The Supreme Court affirmed on appeal. Appellant later filed a motion for postconviction relief, alleging twelve claims. After an evidentiary hearing, the postconviction court denied Appellant’s motion to the extent that it requested a new guilt phase but granted the motion to the extent that it requested a new penalty phase. Appellant appealed and filed a petition for a writ of habeas corpus. The Supreme Court affirmed the postconviction court’s order and denied Appellant’s habeas petition, holding (1) the postconviction court did not err in denying Appellant’s request for a new guilt phase trial; and (2) Appellant failed to establish that he was entitled to habeas corpus relief. View "Blake v. State" on Justia Law

Fla. Stat. 550.054(14)(a), effective July 1, 2010, sets forth the standards a holder of a permit to conduct jai alai must meet to convert the permit to a permit to conduct greyhound racing in lieu of jai alai. Two businesses d applied for the conversion of their jai alai permits on the day section 550.054 became effective. The Department of Business and Professional Regulation, Division of Pari-Mutuel Wagering (DBPR) granted the applications. Thereafter, Appellees instituted a declaratory judgment alleging that section 550.054(14) was an unconstitutional special law. The trial court entered judgment in favor of the two businesses and DBPR, concluding that the statute was a general law. The First District reversed, concluding that section 550.054(14)(a) was unconstitutional. The Supreme Court reversed, holding that the statute is a valid general law. View "Fla. Dep’t of Bus. & Prof’l Regulation v. Debary Real Estate Holdings, LLC" on Justia Law

In 2012, individuals and groups challenging the constitutional validity of a 2012 congressional redistricting plan issued a subpoena duces tecum to Pat Bainter, the president of Data Targeting, Inc., a political consulting company. The challengers sought certain documents in the possession of Bainter, Data Targeting, and the company's employees (collectively, Appellants) related to the redistricting litigation. Bainter did not file a motion for a protective order or raise any legal objection to producing the documents sought by the challengers but instead attended a deposition testifying that he had produced what he had found, which was a limited amount. After being served with additional subpoenas duces tecum including the disputed documents within their scope, and during six months of hearings and filings regarding document production, Appellants did not raise any claim of a First Amendment privilege. It was only after Appellants were held in contempt of court that Appellants raised a belated claim of a qualified First Amendment privilege. Ultimately, the trial court ordered that Appellants produce 538 pages of the disputed documents. The Supreme Court affirmed, holding that, based on the totality of the circumstances, Appellants’ belated assertions of a qualified First Amendment privilege had been waived. View "Bainter v. League of Women Voters of Fla." on Justia Law

Due to a dispute between the Citrus County Hospital Board and the Citrus Memorial Health Foundation, Inc., the Legislature enacted a special law that reeancted the Board’s charter. Section 16 of the charter included subsections that specifically addressed the Board’s relationship with the Foundation. The Foundation filed suit against the Board seeking a declaratory judgment that the the special law was an unconstitutional impairment of the parties’ contracts. The circuit court granted summary judgment for the Board, concluding (1) the Foundation was prohibited from challenging the constitutionality of the special law because it was a public or quasi-public corporation; and (2) the special law did not impair the Foundation’s contracts. The First District Court of Appeal reversed, holding that, as applied to the Foundation, the special law significantly altered the parties’ contractual rights and was an unconstitutional impairment of their contracts. The Supreme Court affirmed, holding (1) the Contract Clause of the Florida Constitution applies to the Foundation’s contracts; and (2) as applied, the special law unconstitutionally impairs the Foundation’s contracts. View "Citrus County Hosp. Bd. v. Citrus Memorial Health Found., Inc." on Justia Law

Appellant pleaded no contest to two counts of first-degree murder and one count of sexual battery on a child under the age of twelve. After a capital penalty-phase trial, the trial court sentenced Appellant to death for the murder of his stepdaughter. The Governor signed the death warrant on September 22, 2014. Appellant subsequently filed a second successive motion for postconviction relief, presenting three claims. The trial court denied the motion. The Supreme Court affirmed, holding (1) Appellant was not entitled to relief on his claim that postconviction counsel rendered ineffective assistance; (2) Appellant’s claim that Florida’s lethal injection protocol violates the prohibition against cruel and unusual punishment did not warrant reconsideration of the Court’s prior decisions upholding the constitutionality of the current protocol; and (3) the trial court did not abuse its discretion in sustaining objections made by various agencies to Appellant’s public records requests. View "Banks v. State" on Justia Law

At issue in this case was whether the use of real time cell site location information to track a defendant violates the Fourth Amendment if probable cause was not provided to access and use that information. Defendant moved to suppress the evidence derived from the real time cell site information obtained from his cell phone for lack of probable cause. The trial court denied the motion, concluding that the application for the order obtained by officers authorizing them to obtain the information did not contain a sufficient factual basis on which to issue a search warrant but that a warrant was not required to use Defendant’s real time cell site location data to track him on public streets where he had “no expectation of privacy.” The Fourth District affirmed. The Supreme Court quashed the decision of the Fourth District, holding (1) Defendant had a reasonable expectation of privacy in the location signals transmitted solely to enable the private and personal use of his cell phone, even on public roads, and therefore, probable cause was required; and (2) probable cause did not support the search in this case, and the evidence obtained as a result of this search was subject to suppression. Remanded. View "Tracey v. State" on Justia Law

Defendant was charged with several offenses, but the trial court entered an order declaring Defendant incompetent to proceed to trial. The trial court later held a competency hearing, during which defense counsel stipulated that Defendant was competent to proceed. The court did not enter a written order determining that Defendant was competent to proceed to trial, but the matter nevertheless proceeded to a jury trial. Defendant was found guilty of two charges. On appeal, Defendant argued that the lack of a written order adjudicating him competent required reversal of his conviction and a new trial. The Fifth District Court of Appeal affirmed, concluding that the lack of a written order could be cured without a new trial because the trial court found Defendant competent based upon the stipulation of defense counsel. The Supreme Court quashed the judgment of the Fifth District in part, holding (1) Defendant’s stipulation as to his own competency did not absolve the trial court from its duty to independently make a determination of Defendant’s competency to proceed; and (2) the remedy for such a violation depends upon the circumstances of each case. View "Dougherty v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, kidnapping, and sexual battery. Defendant was sentenced to death for the murder conviction. On appeal, Defendant challenged only the propriety of the death sentence. The Supreme Court affirmed the convictions and sentence of death, holding (1) the evidence was sufficient to support the convictions; (2) the trial court did not fail to remain neutral during the penalty-phase proceedings; (3) the trial court’s findings on aggravators and mitigators were not in error with the exception of its finding of an avoid arrest aggravator, which error was harmless beyond a reasonable doubt; (4) Defendant was not entitled to relief on his claim that his death sentence was unconstitutional based on Ring v. Arizona; and (5) the death sentence in this case was a proportionate penalty. View "Davis v. State" on Justia Law

Appellant was convicted of murder and sentenced to death. The trial court subsequently ordered a new trial, after which Appellant was again convicted of murder and sentenced to death. Appellant later filed a postconviction motion. The postconviction court ultimately denied Appellant’s postconviction motion. Appellant appealed the denial of his postconviction motion and filed a petition for a writ of habeas corpus. The Supreme Court affirmed the postconviction court’s denial of Appellant’s claims and denied habeas corpus relief, holding (1) the postconviction court properly found that Appellant was competent to proceed with his postconviction proceedings, correctly denied Appellant’s prosecutorial misconduct claim, and properly denied Appellant’s claim of a Brady violation; and (2) Appellant was not entitled to habeas relief based on his claims of ineffective assistance of appellate counsel. View "Huggins v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant’s convictions and sentences on appeal. Defendant later filed a motion for postconviction relief, raising twenty-nine claims. The circuit court denied each of Defendant’s claims. Defendant appealed the denial of five claims and filed a petition for a writ of habeas corpus, raising two additional claims. The Supreme Court affirmed the postconviction court’s denial of Defendant’s claims and denied Defendant’s petition for a writ of habeas corpus, holding (1) the postconviction court properly denied Defendant’s claims of Brady violations, ineffective assistance of trial counsel, improper juror communication, and cumulative error; and (2) Appellant was not entitled to habeas relief based on alleged ineffective assistance of appellate counsel. View "Whitton v. State" on Justia Law