Justia Florida Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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After a second jury trial, Appellant was convicted of first-degree murder and robbery and was sentenced to death. The Supreme Court affirmed the convictions but twice remanded for new penalty phases. Each time, the trial court sentenced Defendant to death. The Supreme Court affirmed the sentence of death. Appellant subsequently moved to vacate judgment of convictions and sentences, alleging ineffective assistance of counsel. The postconviction court denied all claims presented in Appellant’s motion to vacate. The Supreme Court affirmed, holding that the postconviction court did not err in denying Appellant’s claims of ineffective assistance of counsel during his second guilt phase trial and during his fourth penalty phase trial.View "Lebron v. State" on Justia Law

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The Florida Attorney General petitioned the Supreme Court for an advisory opinion as to the validity of a proposed citizen initiative amendment to the Florida Constitution and the accompanying Financial Impact Statement. Upon review, the Supreme Court approved the proposed amendment and Financial Impact Statement for placement on the ballot, concluding (1) the proposed amendment satisfies the single-subject requirement of Fla. Const. art. XI, 3 because it embraces a single subject, which is the medical use of marijuana; (2) the ballot title and summary comply with the clarity requirements of Fla. Stat. 101.161(1) because they give voters fair notice as to the chief purpose and scope of the proposed amendment and will not affirmatively mislead voters regarding the purpose of the proposed amendment; and (3) the Financial Impact Statement complies with Fla. Stat. 100.371(5).View "Advisory Opinion to the Attorney General Re Use of Marijuana for Certain Medical Conditions" on Justia Law

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After a jury trial, Defendant was found guilty of first-degree murder under the felony murder and premeditated theories in the deaths of Berthum Gibson and Keenethia Keenan and guilty of first-degree murder under the felony murder theory in the death of Desmond Robinson. Defendant was sentenced to death for the deaths of Gibson and Keenan. The Supreme Court affirmed the convictions and sentences, holding (1) the evidence was sufficient to support Defendant’s convictions under both the felony murder and premeditation theories; (2) the trial court did not err in giving additional weight to the felony murder aggravating circumstance; (3) Defendant’s death sentences were proportional; and (4) Defendant’s death sentences were not unconstitutional under Ring v. Arizona.View "Smith v. State" on Justia Law

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After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed on direct appeal. Defendant subsequently filed an amended motion to vacate his judgment and sentence, which the postconviction court denied. Defendant appealed and filed an accompanying petition for writ of habeas corpus. The Supreme Court affirmed, holding (1) the postconviction court did not err in finding Defendant competent to proceed in his postconviction proceedings; (2) the postconviction court did not err in denying Defendant’s claim of ineffective assistance of trial counsel during the penalty phase and voir dire; (3) the postconviction court did not err in summarily denying Defendant’s claim that trial counsel was ineffective for failing to file a motion for a change of venue; (4) Florida’s method of execution for lethal injection is constitutional; and (5) Defendant was not entitled to relief on his claim that his right against cruel and unusual punishment would be violated because he may be incompetent at the time of execution.View "Franklin v. State" on Justia Law

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Defendant was convicted of first-degree murder, kidnapping, and sexual battery with great force. Defendant was sentenced to death. The Supreme Court affirmed Defendant’s convictions and sentence of death. Defendant subsequently filed a motion for postconviction relief, raising several allegations of error. The postconviction court denied the motion. The Supreme Court affirmed the postconviction court’s denial of relief and denied Defendant’s petition for a writ of habeas corpus, holding (1) trial counsel did not provide ineffective assistance; (2) Defendant was not entitled to relief on his claims relating to the State’s alleged use of Defendant’s co-defendant as a state agent and letters written between the co-defendant and Defendant; and (3) appellate counsel did not provide ineffective assistance. View "Johnson v. State" on Justia Law

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Appellant, a prisoner under a sentence of death for whom a death warrant had been signed, filed a successive motion for postconviction relief raising an as-applied challenge to Florida’s lethal injection protocol based on his allegation that he suffers from the medical condition porphyria. The circuit court denied Appellant’s claim without an evidentiary hearing. Appellant appealed and produced an affidavit by a physician stating that, in the physician’s expert medical opinion, a substantial risk existed that the use of midazolam hydrochloride as the first drug of Florida’s lethal injection protocol would cause Appellant “extreme or excruciating pain.” In light of these allegations, the Supreme Court relinquished jurisdiction to the circuit court. After a hearing, the circuit court denied Appellant’s claim. The Supreme Court affirmed, holding that Appellant failed to demonstrate that Florida’s lethal injection protocol, as applied to him, violated the Eighth Amendment because he did not show that allegedly suffering from porphyria creates a “substantial risk of serious harm” upon the injection of midazolam. View "Davis v. State" on Justia Law

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Appellant was convicted after a jury trial for the first-degree murders of an elderly couple, whom he cut and stabbed. Sentences of death were imposed for both murders, but the case returned to the circuit court. After a new penalty phase, Appellant was sentenced to death for only one murder. The Supreme Court affirmed Appellant's sentence of death. Appellant sought postconviction relief, alleging ineffective assistance of counsel. After an evidentiary hearing, the postconviction court concluded that Appellant was entitled to a new penalty phase trial. The Supreme Court reinstated Appellant's sentence of death, holding that Appellant was not entitled to any relief due to ineffective assistance of counsel under the Strickland v. Washington standard. View "State v. Woodel" on Justia Law

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Defendant was charged with drug trafficking and possession after the vehicle he was driving was stopped by a deputy sheriff who had noticed an inconsistency between the actual color of the vehicle and the color indicated on the vehicle’s registration. Defendant moved to suppress the results of the stop as products of an unlawful, warrantless search. The trial court denied the motion to suppress, concluding that the vehicle was legally stopped for investigative purposes and that the odor of marijuana emanating from inside the vehicle gave the officer probable cause to conduct a search. Defendant was subsequently convicted. The district court reversed the denial of Defendant’s motion to suppress, concluding that a color discrepancy alone does not provide reasonable suspicion for an investigatory stop. The Supreme Court affirmed, holding that a color discrepancy, standing alone, does not justify initiating a stop to determine if the law has been violated. View "State v. Teamer" on Justia Law

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After a jury trial, Richard England was found guilty of first-degree premeditated murder and felony murder and robbery with a deadly weapon. The trial court sentenced Petitioner to death. England later filed a petition for postconviction relief, alleging ineffective assistance of counsel. The postconviction court denied relief on all claims. Petitioner appealed and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of postconviction relief, holding that the postconviction did not err in concluding that counsel provided constitutionally effective assistance during both the guilt phase and penalty phase of trial. The Court also denied habeas relief, holding that England failed to establish that appellate counsel was ineffective, and the remainder of his claims were procedurally barred or without merit. View "England v. State" on Justia Law

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In 1980, Appellant was convicted of first-degree murder and sentenced to death. After the Governor signed the death warrant in this case, Appellant filed a successive motion for postconviction relief seeking to vacate his judgments of conviction and sentence of death. Appellant also filed motions for disclosure of public records, discovery, and for a stay. The circuit court summarily denied the motions and postconviction claims. The Supreme Court temporarily relinquished jurisdiction for the purpose of holding an evidentiary hearing on the sole issue of the safety and efficacy of the new drug in the lethal injection procedure. After an evidentiary hearing, the circuit court rejected the claim that the use of midazolam hydrochloride as the first drug in the three-drug lethal injection protocol would result in a substantial risk of serious harm and, accordingly, held that the protocol was constitutional. The Supreme Court (1) affirmed the circuit court's order denying postconviction relief on the claims raised in Appellant's successive postconviction motion; but (2) reversed the circuit court's order denying Appellant's public records request for copies of his own inmate and medical records and ordered transmission of copies of those records to Appellant's counsel.View "Muhammad v. State" on Justia Law