Justia Florida Supreme Court Opinion Summaries

Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant's conviction and death sentence on direct appeal. Defendant subsequently filed a motion for postconviction relief. The trial court denied the motion after an evidentiary hearing. The Supreme Court remanded for a new evidentiary hearing, after which the circuit court issued an order denying postconviction relief on all claims. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus. The Court affirmed the denial of Defendant's motion for postconviction relief and denied his habeas petition, holding (1) the State did not commit Brady v. Maryland violations during trial or violate Giglio v. United States by failing to correct false or misleading testimony; (2) Defendant was given effective assistance of counsel at trial; (3) Defendant's claims that he was tried while incompetent were procedurally barred and without merit; and (4) because Defendant failed to demonstrate either deficient performance or prejudice on the part of his trial counsel, his habeas petition failed. View "Wickham v. State" on Justia Law

After a jury trial, Defendant was convicted of robbery and possession of a firearm by a convicted felon. The trial court sentenced Defendant to fifty years' incarceration on the robbery conviction and fifteen years' incarceration on the possession conviction. Defendant appealed the denial of his motion to suppress the search of information stored within his cell phone incident to his arrest. The court of appeal affirmed the trial court's decision in the admissibility of images found on Defendant's cell phone but certified a question to the Supreme Court as a matter of great public importance. The Supreme Court quashed the decision of the court of appeal and remanded, holding (1) the holding in United States v. Robinson does not allow a police officer to search through photographs contained within a cell phone that is on an arrestee's person at the time of a valid arrest; and (2) while law enforcement officers properly separated and assumed possession of a cell phone from Defendant's person during the search incident to arrest, a warrant was required before the information, data, and content of the cell phone could be accessed and searched by law enforcement. View "Smallwood v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended the death penalty by a vote of seven to five, and the trial court sentenced Defendant to death. The Supreme Court affirmed. Defendant subsequently filed a second amended initial motion for postconviction relief and supplemental addendum, presenting several claims. The postconviction court denied the motion and addendum. The Supreme Court affirmed the denial of Defendant's motion, holding (1) Defendant was afforded effective assistance of counsel at trial; (2) Defendant was not entitled to a claim of cumulative error because he failed to prevail on any individual claim of ineffectiveness; and (3) Defendant was not entitled to relief on his claims that Florida's death penalty violates Ring v. Arizona and is unconstitutional. View "McCoy v. State" on Justia Law

After a jury trial, Defendant was convicted of the first-degree murders of two Clearwater residents and received two sentences of death. The Supreme Court affirmed the trial court's judgments of conviction and sentences of death, holding (1) Defendant's argument that his penalty phase counsel penalty provided ineffective assistance did not warrant relief on direct appeal, as ineffective assistance of counsel claims are not cognizable on direct appeal; (2) Defendant's death sentences were not unconstitutional because they were based on a seven-to-five bare majority recommendation by the jury; (3) the trial court did not commit error in suggesting to the State that it seek the prior capital felony aggravating circumstance; (4) the State's closing argument during the guilt phase did not warrant a new trial; (5) substantial evidence supported each of Defendant's convictions; and (6) Defendant's death sentences were proportional to similar cases where the Court affirmed the sentence of death. View "Robards v. State" on Justia Law

In 1972, Petitioner was convicted and sentenced to life imprisonment for committing capital sexual battery. In a separate case, Petitioner pled guilty to of unlawful use of a motor vehicle. From 1992 forward, Petitioner filed multiple pro se extraordinary writ petitions and other proceedings with the Supreme Court seeking relief from his conviction and sentence. None of the petitions for relief was granted. In the instant case, Petitioner filed pro se petitions for writs of habeas corpus. The Court dismissed the petitions as unauthorized pursuant to Baker v. State and found them to be frivolous proceedings. Because the petitions were dismissed as unauthorized and also were the ninth and tenth pro se proceedings initiated by Petitioner in the Court, and because Petitioner failed to show cause why he should not be sanctioned, the Court instructed the clerk of court to reject any future pleadings, petitions or filings submitted by Petitioner related to his criminal cases. View "McCutcheon v. State" on Justia Law

Defendant was convicted of first-degree murder and robbery with a deadly weapon. Defendant appealed, arguing that the trial judge erred in refusing to allow Defendant to call a witness despite defense counsel's determination that calling the witness would not be of benefit to Defendant's case. The Fourth District court of appeal held that determining which witnesses should be called by the defense is not a fundamental decision to be made by the defendant himself, and therefore, the trial court did not err in its judgment. The Fourth District subsequently certified conflict with the Fifth District's decision in Cain v. State. The Supreme Court (1) approved the decision of the Fourth District in this case and disapproved the decision of the Fifth District in Cain, holding that defense counsel has the final authority as to whether or not the defense will call a particular witness to testify at the criminal trial; and (2) receded from its decision in Blanco v. State to the extent it held that the ultimate decision rests with the defendant as to the presentation of witnesses. View "Puglisi v. State" on Justia Law

Petitioner was convicted under Fla. Stat. 790.19 for shooting into an unoccupied vehicle. The trial court determined Petitioner qualified as a prison releasee reoffender (PRR) under the forcible felony catch-all provision of the PRR statute and thus sentenced him to a prison term of fifteen years for the conviction. Petitioner filed a motion for postconviction relief disputing the validity of his sentence, claiming that his conviction was not a qualifying felony under the forcible felony catch-all provision of the PRR statute. The trial court denied the motion, and the fourth district court of appeal affirmed. The court, however, certified conflict with the first district's decision in Crapps v. State. The Supreme Court (1) approved the fourth district's decision, finding that the offense of shooting into an occupied vehicle necessarily involves the use or threat of physical force or violence against an individual, and therefore, qualifies as a forcible felony under the catch-all provision of the PRR statute; and (2) disapproved the opinion in the conflicting case of Crapps. View "Paul v. State" on Justia Law

Plaintiffs filed a class action complaint against a check advance company, asserting claims based on numerous Florida statutes. Plaintiffs later amended the complaint to add Tiffany Kelly as an additional plaintiff and named class member. Because Kelly had signed the version of Defendant's arbitration agreement that contained a class action waiver, this case focused on her contracts with Defendant. The trial court eventually denied Defendant's motion to compel arbitration, ruling that the class action waiver was unenforceable because it was void as against public policy. The court of appeal affirmed, finding that no other reasonable avenue for relief would be available if it enforced the class action waiver. After the court of appeal decided this case, the U.S. Supreme Court issued its decision in AT&T Mobility, LLC v. Concepcion. Applying the rationale of Concepcion to the facts set forth in this case, the Supreme Court quashed the court of appeal's decision, holding that the Federal Arbitration Act preempted invalidating the class action waiver in this case on the basis of the waiver being void as against public policy. View "McKenzie Check Advance of Fla., LLC v. Betts" on Justia Law

After Defendant, an inmate, committed several sexual offenses in Florida and Georgia, the state attorney initiated civil commitment proceedings against him under the Jimmy Ryce Act. Almost four years later, Defendant, who was still in custody, filed a motion to dismiss the commitment petition, arguing that he was not in lawful custody at the time commitment proceedings were initiated because his sentence had expired due to postconviction credit for time previously served. The circuit court denied the motion to dismiss based on its determination that Defendant was in lawful custody when commitment proceedings were initiated. The district court dismissed the commitment petition and ordered the immediate release of Defendant from custody, concluding that the circuit court did not have jurisdiction to adjudicate the commitment petition because Defendant was not in lawful custody when the State initiated commitment proceedings. The Supreme Court approved the district court's decision, holding that Defendant was not in lawful custody at the time the commitment procedures were initiated because his incarcerative sentence had already expired. View "State v. Phillips" on Justia Law

Defendant was convicted and sentenced to death for the kidnapping and murder of a ten-year-old. The Supreme Court affirmed Defendant's conviction on direct appeal but remanded for resentencing. After resentencing, when Defendant was again sentenced to death, the Supreme Court affirmed Defendant's sentence. Defendant filed several postconviction motions, which were denied. Defendant filed the instant motion to vacate sentence and requested certain public records after his execution date was set. The circuit court summarily denied relief on all claims. Defendant appealed and filed a petition for a writ of habeas corpus. The Supreme Court affirmed and denied habeas corpus relief, holding (1) the majority of Defendant's claims were without merit; (2) the circuit court properly denied Defendant's records requests because the requested records were not relevant to a colorable claim; and (3) Defendant's petition for habeas corpus was untimely. View "Mann v. State" on Justia Law