Justia Florida Supreme Court Opinion Summaries

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

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

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

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

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

Appellant was convicted of first-degree murder, burglary of a battery therein, and sexual battery with great force. Appellant was sentenced to death. The Supreme Court upheld the convictions and death sentence on appeal and later upheld the denial of postconviction relief and denied habeas relief. After Appellant was scheduled for execution, he filed a successive postconviction motion, claiming that Florida's death penalty statute violated the Eighth Amendment because most states require a unanimous jury verdict to recommend a death sentence and because alleged newly discovered evidence revealed that the number of defendants sentenced to death in Florida increased in 2012 compared to the rest of the nation. The circuit court denied relief. The Supreme Court affirmed, holding (1) non-unanimous jury recommendations to impose the sentence of death are not unconstitutional; and (2) the circuit court accurately found that the studies cited by Appellant in support of his second claim did not qualify as newly discovered evidence. View "Kimbrough v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder, attempted first-degree murder, grand theft of a motor vehicle, home invasion robbery, and aggravated assault on a police officer. The trial court imposed a sentence of death for the murder conviction. The Supreme Court affirmed the convictions and sentences. Appellant subsequently filed a motion to vacate his conviction and sentence of death pursuant to Fla. R. Crim. P. 3.851, presenting ten claims. The postconviction court summarily denied all claims except Appellant’s claim of ineffective assistance of counsel. After an evidentiary hearing, the postconviction court denied Appellant’s ineffective assistance of counsel claim. The Supreme Court affirmed the trial court’s order denying postconviction relief, holding (1) Appellant’s trial counsel were not ineffective; and (2) Appellant’s challenges to the death penalty in Florida were either waived, procedurally barred, meritless, or premature. View "Turner v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder and one count of armed carjacking. The trial court sentenced Defendant to death on both murder counts. The Supreme Court affirmed Defendant’s convictions and sentences. Defendant subsequently filed a motion for postconviction relief, raising twenty-eight claims. After an evidentiary hearing, the circuit court denied relief. Defendant appealed the denial of his postconviction motion, raising twenty-one claims, and also petitioned the Supreme Court for a writ of habeas corpus, raising two claims of ineffective assistance of appellate counsel. The Supreme Court affirmed the postconviction court’s denial of relief on all claims and denied habeas corpus relief, holding (1) Defendant failed to establish that any errors occurred that, either individually or cumulatively, would entitle him to a new guilt phase trial; and (2) Defendant’s claims of ineffective assistance of appellate counsel were procedurally barred. View "Deparvine v. State" on Justia Law

Plaintiff filed a lawsuit against Defendant, her former employer, alleging that Defendant took adverse employment actions against her after she revealed that she was pregnant. The trial court dismissed Plaintiff’s lawsuit for failure to state a cause of action. The court of appeal affirmed, concluding that Florida law does not prohibit pregnancy discrimination in employment practices. The Supreme Court quashed the court of appeal’s decision and remanded with directions that the trial court reinstate Plaintiff’s complaint, holding that the provision in the Florida Civil Rights Act (FCRA) making it an unlawful employment practice for an employer to discriminate based on an individual’s sex includes discrimination based on pregnancy, which is “a natural condition and primary characteristic unique to the female sex.” View "Delva v. Continental Group, Inc. " on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder. Appellant was sentenced to death for the murders. The Supreme Court affirmed the convictions and sentences. Appellant subsequently filed a motion to vacate the convictions and sentences pursuant to Fla. R. Crim. P. 3.851, asserting four claims. The postconviction court summarily denied Appellant’s motion without an evidentiary hearing. Appellant appealed the summary denial of his motion and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of the Rule 3.851 motion and denied the petition for writ of habeas corpus, holding, among other things, that (1) Appellant was afforded constitutionally effective assistance of trial counsel; (2) Appellant’s allegation of improper argument by the prosecution was procedurally barred; and (3) Appellant’s claim that to execute him would be unconstitutional because he was mentally ill was without merit. View "McKenzie v. State" on Justia Law