Justia Florida Supreme Court Opinion Summaries

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

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

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

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

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

Defendant pled guilty to first-degree murder with a firearm. After a penalty-phase proceeding conducted before a jury, the trial court imposed the death sentence for the murder. The Supreme Court affirmed the conviction and sentence of death, holding (1) the trial court did not abuse its discretion in finding and assigning great weight to a cold, calculated, and premeditated (CCP) aggravator; (2) Defendant's death sentence was a proportionate punishment in this case; (3) Defendant failed to present any compelling reason for the Court to reconsider its established precedent on the issue of whether a mental illness rendered Defendant's execution unconstitutional; and (4) Defendant's guilty plea was knowingly, intelligently, and voluntarily entered. View "McCoy v. State" on Justia Law

Appellant was convicted of first-degree murder, attempted first-degree murder, and related crimes. The jury recommended that Appellant be sentenced to death, and the judge followed the jury’s recommendation. On appeal, the Supreme Court vacated Appellant’s death sentence based on the cumulative effect of errors made during the penalty phase of the trial. Following a new penalty phase, the trial court again sentenced Appellant to death. The Supreme Court upheld the trial court’s imposition of the death penalty on resentencing, holding (1) the trial court did not abuse its discretion in allowing the State’s strikes of two African American venirepersons; (2) the trial court did not abuse its discretion in allowing the State to introduce the severed fingertip of one of the victims into the new penalty phase; (3) the prosecutor engaged in improper arguments, but the errors were harmless; and (4) the death sentence in this case was appropriate. View "Poole v. State" on Justia Law

Appellant murdered an eleven-year-old girl while on duty as a police officer. After a jury trial, Appellant was convicted of sexual battery and first-degree murder. The trial court sentenced Appellant to death after finding two aggravating factors. The Supreme Court affirmed Appellant’s convictions and sentences on appeal. This appeal concerned the circuit court’s order summarily denying Appellant’s successive motion for postconviction relief in which Appellant claimed, among other things, that newly discovered evidence demonstrated that an FBI analyst’s testimony at trial regarding hair evidence was erroneous. The Supreme Court affirmed, holding (1) because Appellant’s successive motion constituted relitigation of the same hair-analysis issues that Appellant previously raised, without success, he was not entitled to any relief; and (2) the postconviction court did not err in denying relief on Appellant’s remaining claims. View "Duckett v. State" on Justia Law

After a jury trial, Charles Peterson was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed the conviction and sentence. Peterson subsequently filed a postconviction motion in the circuit court, alleging ineffective assistance of counsel. The postconviction court denied relief. Peterson appealed the denial of his postconviction motion and also petitioned for a writ of habeas corpus, claiming that his appellate counsel provided ineffective assistance. The Supreme Court affirmed the postconviction court’s denial of relief and denied Peterson’s petition for a writ of habeas corpus, holding (1) Peterson’s claims that his trial counsel should have challenged certain jurors for cause and failed to effectively use peremptory challenges were without merit; (2) trial counsel was not ineffective for failing to challenge in- and out-of-court identifications; and (3) appellate counsel was deficient for providing incorrect information to the Court, but appellate counsel’s misstatement did not compromise the appellate process to such a degree as to undermine confidence in the correctness of the result. View "Peterson v. State" on Justia Law

Plaintiffs brought lawsuits challenging the validity of the 2012 congressional apportionment plan (Plan) under the Florida Constitution's redistricting standards. At issue before the Supreme Court was whether Florida state legislators and legislative staff members had an absolute privilege against testifying as to issues directly relevant to whether the Legislature drew the Plan with unconstitutional partisan or discriminatory intent. The circuit court permitted the discovery of information and communications, including the testimony of legislators, pertaining to the constitutional validity of the Plan. The court of appeal reversed, holding that the legislators had the absolute protection of a legislative privilege. The Supreme Court quashed the court of appeal's decision and approved the circuit court's order, holding (1) Florida recognizes a legislative privilege founded on the constitutional principle of separation of powers; but (2) this privilege is not absolute where, as in this case, the purposes underlying the privilege are outweighed by the compelling, competing interest of effectuating the explicit constitutional mandate that prohibits partisan political gerrymandering and improper discriminatory intent in redistricting.View "League of Women Voters of Fla. v. Fla. House of Representatives" on Justia Law