Justia Florida Supreme Court Opinion Summaries

Michelle McCall received prenatal medical care at a United States Air Force clinic as an Air Force dependent. McCall died after delivering her son as a result of severe blood loss. Petitioners filed an action against the United States under the Federal Tort Claims Act (FTCA). The federal district court found the United States liable under the FTCA. The court concluded that Petitioners’ economic damages amounted to $980,462 and Petitioners’ noneconomic damages totaled $2 million. However, the district court limited Petitioners’ recovery of wrongful death noneconomic damages to $1 million after applying Fla. Stat. 766.118, Florida’s statutory cap on wrongful death noneconomic damages based on medical malpractice claims. The district court subsequently denied Petitioners’ motion challenging the constitutionality of the wrongful death statutory cap. The Eleventh Circuit Court of Appeals affirmed the application of the statutory cap on noneconomic damages and held that the statute was not unconstitutional. The Florida Supreme Court accepted certification to answer questions of Florida law and answered by holding the statutory cap on wrongful death noneconomic damages provided in Fla. Stat. 766.118 violates the Equal Protection Clause of the Florida Constitution. View "Estate of McCall v. United States" on Justia Law

Defendant was convicted of two counts of first degree murder, burglary and robbery. On remand, the trial court imposed a sentence of death for one of the murders. The Supreme Court affirmed. Defendant subsequently filed a motion for postconviction relief, alleging, among other things, that he was denied the effective assistance of counsel. The postconviction court granted Defendant’s motion to the extent that he was entitled to a new penalty phase trial based on ineffective assistance of counsel. The Supreme Court reversed the postconviction court’s judgment that Defendant be afforded a new penalty phase, as counsel did not provide constitutionally ineffective assistance under Strickland v. Washington, and otherwise affirmed. View "State v. Woodel" on Justia Law

Appellant and his codefendant were convicted of kidnapping and first-degree murder. Appellant was sentenced to death. After the Supreme Court affirmed Appellant’s convictions and sentence, Appellant filed a motion to vacate his judgment of conviction for murder and his death sentence and also filed a motion for DNA testing. The postconviction court denied postconviction relief and denied DNA testing. The Supreme Court affirmed, holding that the postconviction court did not err in (1) denying relief on some of Appellant’s ineffective assistance of counsel claims after an evidentiary hearing; (2) summarily denying the remainder of Appellant’s ineffective assistance of counsel claims; and (3) denying Appellant’s motion for postconviction DNA testing. View "Jackson v. State" on Justia Law

After a jury trial, Petitioner was convicted of the first-degree murders of his two stepdaughters. The trial court sentenced Petitioner to death for each of the murders. The Supreme Court affirmed Petitioner's convictions and sentences on appeal. The Office of Capital Collateral Regional Counsel filed Petitioner's initial postconviction motion, but Petitioner refused to sign the required verification of the motion. After granting extensions of time and giving Petitioner numerous opportunities to file a verified motion, the trial court dismissed the unverified postconviction motion with prejudice. Petitioner appealed and also filed a petition for writ of habeas corpus claiming that the trial court erred in allowing him to proceed pro se at trial. The Supreme Court affirmed, holding (1) the trial court did not err in determining that Petitioner was competent to proceed with postconviction litigation; (2) the trial court did not err in dismissing Petitioner's postconviction motion with prejudice for failing to file a facially sufficient motion; and (3) Petitioner's petition for habeas corpus as relief was not warranted. View "Hernandez-Alberto v. Crews" on Justia Law

In 1986, Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed on appeal. Defendant subsequently filed a motion for postconviction relief, which the trial court denied after an evidentiary hearing. The Supreme Court remanded for a new evidentiary hearing. After a new evidentiary hearing was held in 2010, the circuit court denied postconviction relief on all claims. Defendant appealed the denial of his postconviction motion and petitioned for a writ of habeas corpus. The Supreme Court affirmed the denial of Defendant's postconviction petition and denied Defendant's petition for habeas corpus, holding (1) the circuit court did not err in denying Defendant's postconviction claims on the basis that they were either procedurally barred, refuted by the record, or otherwise without merit; and (2) Defendant did not show he was entitled to habeas relief where he failed to demonstrate either deficient performance on the part of his appellate counsel or prejudice. View "Wickham v. State" on Justia Law

Defendant pled guilty to carrying a concealed firearm and possession of a firearm by a convicted felon. Defendant appealed, arguing that the trial court erred by denying his motion to suppress the firearm, his identity as a convicted felon, and statement he made after he was detained by the police. In particular, Defendant alleged that the arresting officer lacked reasonable suspicion to conduct the Terry stop because no facts were presented to indicate that Defendant did not possess a license to carry the firearm. The court of appeal affirmed but certified conflict with Regalado v. State on the issue of whether an officer who believes that someone is carrying a concealed firearm, without more, has reasonable suspicion to conduct a Terry stop. The Supreme Court affirmed, holding (1) given the differing factual circumstances that preceded the stops in Regalado and in this case, no actual conflict existed; and (2) the court of appeal did not err in finding that the Terry stop of Defendant was valid. View "Mackey v. State" on Justia Law

Defendant was convicted of two counts of first-degree murder, two counts of attempted first-degree murder, and burglary of a dwelling. The trial court imposed death sentences for the murders of both victims. Defendant appealed, raising several issues with regard to the penalty phase that led to the imposition of the death sentences. The Supreme Court affirmed Defendant's convictions and sentences, holding (1) any error in the trial court's finding of the aggravating factors was harmless beyond a reasonable doubt; (2) the trial court did not err in allowing victim impact statements or in admitting photographs of the murder victims; (3) the imposition of the death penalty in this case was proportionate and supported by the applicable aggravating and mitigating factors; and (4) sufficient evidence in the record supported Defendant's convictions. View "Kalisz v. State" on Justia Law

After a jury trial, Defendant was convicted of trafficking in cocaine. Defendant appealed, arguing that the trial court erred by denying his motion for judgment of acquittal on the trafficking charge because the State had not chemically tested each baggie in Defendant's possession for cocaine before commingling and weighing the baggies' contents. The court of appeal affirmed, concluding that the contents of the nine individually wrapped baggies were properly commingled before they were chemically tested and weighed due to the particular circumstances that surrounded the discovery of the bags. The Supreme Court quashed the decision below, holding (1) in cases such as this one, the State must prove through chemical testing that each individually wrapped packet of white powder seized contains at least a mixture of a controlled substance before the State may combine and weigh the commingled substance; and (2) therefore, the trial court in this case should have granted Defendant's motion for judgment of acquittal. Remanded. View "Greenwade v. State" on Justia Law

After a jury trial, Defendant was convicted of the first-degree murder of a high school band teacher. The trial court sentenced Defendant to death. The Supreme Court affirmed on appeal. Defendant later filed a petition for postconviction relief under Fla. R. Crim. P. 3.850, alleging, inter alia, that his trial counsel was ineffective for several reasons. After an evidentiary hearing, the circuit court denied relief. The Supreme Court affirmed the denial of Defendant's motion for postconviction relief, holding (1) the circuit court did not prejudicially err in finding that Defendant's counsel provided effective assistance; and (2) the circuit court did not prejudicially err in summarily denying the remainder of Defendant's claims. View "Foster v. State" on Justia Law

Pursuant to a plea of nolo contendere, Defendant was convicted of sex-related offenses and sentenced to forty-five years' imprisonment. Nearly eleven years after the sentence had been imposed, Defendant filed a motion to withdraw plea arguing that he was entitled to withdraw his plea because the trial court failed formally to accept his plea during the plea colloquy. The postconviction court ruled that the trial court's inadvertent failure to formally accept Defendant's plea did not entitle Defendant to withdraw his plea. The court of appeal affirmed, holding that Defendant was not entitled to withdraw his plea after he was sentenced absent a showing of manifest injustice or clear prejudice. The Supreme Court affirmed, holding that the actual sentencing of a defendant is a sufficient affirmative statement to the parties made in open court and on the record as to constitute formal acceptance of a plea under Fla. R. Crim. P. 3.172(g), and actual sentencing evidences the finality in the proceedings where the right to withdraw a plea is revoked. View "Campbell v. State" on Justia Law