Justia Florida Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
McCoy v. State
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
Poole v. State
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
Duckett v. State
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
Peterson v. State
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
League of Women Voters of Fla. v. Fla. House of Representatives
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
Posted in:
Constitutional Law, Election Law
McLean v. State
Appellant was convicted of first-degree murder and sentenced to death. Appellant’s conviction and death sentence were affirmed on direct appeal. Appellant subsequently filed a motion for postconviction relief, asserting eleven claims. The circuit court denied relief on all of Appellant’s claims. Appellant appealed and filed a petition for a writ of habeas corpus. The Supreme Court affirmed the denial of Appellant’s motion for postconviction relief and denied his habeas petition, holding (1) Appellant’s trial counsel did not provide ineffective assistance during the guilt phase or penalty phases of trial; (2) Appellant’s due process rights were not violated by the State’s institutional policy of reprocessing tape recordings of tips received by Crimeline, a crime reporting hotline, including a recording of a tip that implicated him in the crime of which he was charged; and (3) Appellant’s challenges to Florida’s capital sentencing scheme were without merit. View "McLean v. State" on Justia Law
Moore v. State
Defendant was convicted of robbing and killing Johnny Parrish and burning down Parrish's house. The trial court sentenced Defendant to death for the first-degree murder conviction. Defendant subsequently filed two postconviction motions and two additional petitions for a writ of habeas corpus, all of which were denied. Defendant then instituted this second successive postconviction motion, raising three claims. After an evidentiary hearing, the postconviction court denied relief. The Supreme Court affirmed, holding (1) Defendant failed to meet his burden to demonstrate that the State knowingly presented false or misleading evidence that it failed to correct at Defendant's trial in violation of Giglio v. United States; and (2) Defendant failed to show that newly discovered evidence was of "such a nature that it would probably produce an acquittal on retrial."View "Moore v. State" on Justia Law
Masone v. City of Aventura
In 2010, the legislature amended state law to preempt regulation of red light cameras to the state. At issue in these consolidated cases was whether pre-2010 municipal ordinances imposing penalties for red light violations detected by camera devices were invalid because they were preempted by state law. The district courts in these cases reached contrary conclusions: the Third District Court of Appeal held that the City of Aventura’s ordinance was a valid exercise of municipal power, and the Fifth District Court of Appeal concluded that the City of Orland’s ordinance was invalid because it was in conflict with and was preempted by state law. The Supreme Court agreed with the Fifth District, holding that the ordinances at issue were invalid because they were expressly preempted by state law. View "Masone v. City of Aventura" on Justia Law
Posted in:
Constitutional Law, Government & Administrative Law
Abdool v. Bondi
Petitioners, inmates under a sentence of death, challenged the facial validity of four provisions of the Timely Justice Act of 2013, which was enacted to “reduce delays in capital cases and to ensure that all appeals and postconviction actions in capital cases are resolved as soon as possible after the date a sentence of death is imposed in the circuit court.” The disputed portions of the Act were the provisions that governed conflict of interest and substitute counsel, constitutionally deficient representation, capital postconviction public records production, and the issuance of a warrant of execution. The Supreme Court denied the petition, holding that the challenged provisions of the Act did not facially violate the constitution.
View "Abdool v. Bondi" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Diaz v. State
After a jury trial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed the conviction and sentence on appeal. Appellant subsequently filed a postconviction motion seeking to vacate his conviction and sentence as well as a motion seeking a ruling that he was ineligible to be executed due to mental retardation. The postconviction court denied both motions. Appellant appealed the denial of his motions and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the postconviction court's orders and denied Appellant's habeas petition, holding (1) Appellant was not entitled to relief on any of his claims raised in his motion for postconviction relief; (2) Appellant was not entitled to relief on his mental retardation-related claims; and (3) Appellant's habeas claims were not properly presented in a petition for a writ of habeas corpus, and thus, Appellant was not entitled to habeas corpus relief. View "Diaz v. State" on Justia Law