Justia Florida Supreme Court Opinion Summaries

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

Defendant was convicted of attempted murder, among other crimes, and was sentenced to various terms of imprisonment, including a fifty-five-year term. Defendant's convictions and sentences were affirmed on appeal. After unsuccessfully making a number of filings in the Supreme Court challenging his convictions and sentences, Defendant filed a pro se petition for writ of mandamus with the Court. Because the petition filed in this case was without merit, and because Defendant submitted multiple other meritless filings seeking relief relating to his criminal case that demonstrated an ongoing pattern of abuse of the judicial process, the Court (1) instructed the clerk of court to reject any filings submitted by Defendant relating to his criminal court case; and (2) found Defendant's current petition to be frivolous and directed the clerk of court to forward a copy of this opinion to the Department of Corrections' institution or facility where Defendant was incarcerated. View "Nelson v. Crews" on Justia Law

After a jury trial, Defendant was convicted of kidnapping and first-degree murder. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant's convictions and sentence, holding (1) the trial judge did not err in admitting statements Defendant made to law enforcement because the statements did not constitute similar fact or collateral crime evidence and were otherwise relevant and admissible to establish premeditation; (2) because Defendant's expert testimony opened the door for a witness to testify about allegations of Defendant's past criminal conduct, the trial court properly admitted the testimony and properly excluded the witness from the sequestration rule; (3) substantial, competent evidence supported the trial court's fining that certain aggravating circumstances applied in Defendant's case; (4) the trial court properly rejected the lack of capacity mitigating factor; (5) the evidence was sufficient to support the convictions; and (6) the imposition of the death sentence in this case was proportionate when compared to other death sentences the Court has upheld. View "Hilton v. State" on Justia Law

Defendant was convicted of first-degree murder and kidnapping and sentenced to death for the first-degree murder and to fifteen years' imprisonment for kidnapping. The Supreme Court affirmed on direct appeal. Defendant subsequently filed a motion for postconviction relief. Following an evidentiary hearing, the circuit court denied postconviction relief on all claims. Defendant appealed the circuit court's denial of postconviction relief and also petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of Defendant's postconviction motion and denied his habeas petition, holding (1) the circuit court did not err in concluding that Defendant's postconviction claims were either procedurally barred, conclusively refuted by the record, facially or legally insufficient as alleged, or without merit as a matter of law; and (2) Defendant's counsel provided effective assistance, and therefore, Defendant's claims for habeas relief failed. View "Conahan v. State" on Justia Law

Plaintiff, the personal representative of the estate of Charlotte Douglas, filed a complaint against cigarette companies and industry organizations for damages on claims based on Charlotte's smoking-related death. After a jury trial, Plaintiff was awarded $2.5 million in damages. At issue on appeal was whether the trial court erred in the application of the Phase I findings in the class action case Engle v. Liggett Group, Inc. Charlotte was a member of the Engle class. The court of appeal affirmed, concluding that Plaintiff did not prove legal causation on his negligence theory but did prove legal causation on his strict liability claim. Although the court of appeal rejected Defendants' argument that applying res judicata to the findings violated their due process rights, it certified the due process question to the Supreme Court. The Court approved of the court of appeal's decision affirming the general verdict for Plaintiff based on strict liability but disapproved the court's rejection of negligence as a basis for the general verdict because the court's analysis required causation instructions and findings beyond those required by Engle. In addition, the Court answered that accepting as res judicata the eight Phase I findings approved in Engle did not violate Defendants' due process rights. View "Philip Morris USA Inc. v. Douglas" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death. After his initial postconviction motion was denied, Petitioner filed an amended successive postconviction motion to vacate his judgments and sentence. Defendant filed a motion for discovery with regard his postconviction claim of newly discovered evidence, seeking production of a photograph card of an unidentified fingerprint found on the victim's check, which Defendant sought to compare with that of a deceased death row inmate. The postconviction court denied Defendant's motion for discovery and summarily denied his amended successive postconviction motion. The Supreme Court affirmed, holding (1) the postconviction court correctly summarily denied relief on the postconviction motion, as (i) Defendant's claim was time-barred, and furthermore, the record showed Defendant was not entitled to relief; (ii) Defendant was not entitled to a new trial based on newly discovered evidence; and (iii) Defendant was not deprived of his due process rights to present evidence on his challenge to Florida's lethal injection procedures. The Court also affirmed the circuit court's denial of Defendant's motion for discovery, as Defendant did not show his request would result in discovery of relevant or material evidence. View "Reed v. State" on Justia Law

In 1976, Defendant was convicted of the first-degree murders of his wife Eunice Zeigler and Charlie Mays and the second-degree murders of his in-laws, Perry and Virginia Edwards. In 2001, the trial court granted Defendant's motion for DNA testing for the purposes of clemency proceedings. After the testing was completed, Defendant filed a motion to vacate his sentences, arguing that the presence of Perry's blood on Mays' clothing corroborated his testimony that Mays was a perpetrator rather than a victim. The trial court denied the motion, and the Supreme Court affirmed. In 2009, Defendant filed a motion for postconviction DNA testing requesting further testing of the victims' clothing. Following an evidentiary hearing, the circuit court denied Defendant's motion. The Supreme Court affirmed, holding that Defendant had not met his burden of showing how the results of the DNA testing would give rise to a reasonable probability of a different outcome. View "Zeigler v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and was sentenced to death. The Supreme Court affirmed Defendant's conviction and sentence, holding (1) Defendant's claims regarding the constitutionality of certain aggravators and jury instructions were denied because Defendant provided no reasons that the Court should depart from its precedent upholding the constitutionality of these aggravators and instructions; (2) competent, substantial evidence supported Defendant's murder conviction; and (3) under the totality of the circumstances, Defendant's death sentence was proportional in relation to other death sentences the Court has upheld. View "Matthews v. State" on Justia Law