Justia Florida Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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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

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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

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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

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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

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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

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After a jury trial in 1985, Appellant was convicted of first-degree murder and sexual battery. Appellant later filed a motion for postconviction relief seeking to have his convictions vacated after newly discovered evidence revealed that there was no seminal fluid found in the victim. At the time of Appellant's trial, the Florida law enforcement department tested vaginal and anal swabs of the victim and got a positive result for acid phosphatase (AP). The AP evidence was crucial to the State's case that a sexual battery occurred especially since the victim was found fully clothed and the medical examiner relied on the now-discredited testing that AP was present in order to conclude the victim was sexually battered. The newly discovered evidence also impacted the first-degree murder conviction because without evidence that a sexual battery occurred, the evidence linking Appellant to the murder was scant. The circuit court denied relief. The Supreme Court reversed and vacated Appellant's convictions and sentences, holding that the newly discovered evidence weakened the case against Appellant so as to give rise to a reasonable doubt as to his culpability. Remanded for a new trial.View "Swafford v. State" on Justia Law

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Two women, DMT and TMH, agreed to jointly conceive and raise a child together. The child was conceived through the use of assisted reproductive technology. TMH provided the egg, and DMT gave birth to the child. The couple participated in raising their child together until their relationship ended and DMT absconded with the child. TMH sought to establish her parental rights to the child and to reassume parental responsibilities. The court of appeal concluded that Florida's assisted reproductive technology statute was unconstitutional as applied to TMH because it automatically deprived TMH of her ability to assert her fundamental right to be a parent. The Supreme Court affirmed, concluding that, based on the circumstances of this case, the statute was unconstitutional as applied to abridge TMH's fundamental right to be a parent and violated state and federal equal protection by denying same-sex couples the statutory protection against the automatic relinquishment of parental rights that it affords to heterosexual unmarried couples seeking to utilize the assistance of reproductive technology. Remanded. View "D.M.T. v. T.M.H." on Justia Law

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Petitioners filed a petition for extraordinary writ relief concerning certain documents in the possession of Respondents, non-parties to litigation regarding the constitutional validity of the 2012 plan apportioning Florida’s congressional districts under the Fair Districts Amendments. Petitioners contended that the documents demonstrated “the surreptitious participation of partisan operatives in the apportionment process," but the First District Court of Appeal precluded the admission of the documents. The Supreme Court granted relief to Petitioners and stayed the enforcement of the First District’s order, holding that the circuit court was not precluded from admitting the documents into evidence, subject to a proper showing of relevancy, but that the court must maintain the confidentiality of the documents by permitting disclosure or use only under seal in a courtroom closed to the public. View "League of Women Voters v. Data Targeting, Inc." on Justia Law

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Appellant was convicted of two counts of first-degree murder. The trial court imposed two death sentences after finding several aggravating factors. The Supreme Court affirmed on direct appeal. After Appellant's initial motion for postconviction relief was denied, Appellant filed a motion for DNA testing, which was also denied. Appellant subsequently filed in federal court a petition for a writ of habeas corpus, which was denied. Appellant then filed a successive postconviction motion, claiming that the American Society of Addiction Medicine (ASAM) Public Policy Statement defining addiction as a brain disorder was newly discovered evidence which, if presented to a jury, would probably result in a life sentence. The circuit court summarily denied the claim. The Supreme Court affirmed, holding that the ASAM definition was not newly discovered evidence, and even if the ASAM policy statement was considered to be newly discovered evidence and it was admitted at trial, it was not probable Appellant would receive a life sentence.View "Henry v. State" on Justia Law

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After a jury trial, Appellant was convicted of first-degree murder and kidnapping and sentenced to death. Appellant appealed, arguing, among other things, that (1) the trial court erred in allowing the State to ask a law enforcement officer about statements Appellant made to him during an interview without admitting the entire interview under the rule of completeness; and (2) the trial court erred in finding the avoiding arrest and cold, calculated, and premeditated (CCP) aggravators. The Supreme Court affirmed, holding (1) Appellant failed to properly preserve his first claim, and even if he had, any error in not admitting the statements under the rule of completeness was harmless beyond a reasonable doubt; (2) the trial court erred in finding the avoiding arrest aggravator, but this error was harmless, and there was competent, substantial evidence to support the finding of CCP; (3) there was sufficient evidence to support Appellant's convictions; and (4) the death sentence was proportional in this case.View "Calhoun v. State" on Justia Law