Justia Florida Supreme Court Opinion Summaries

This case arose when defendant was arrested and charged in county court with the misdemeanor offenses of possessing marijuana, possessing drug paraphernalia, and driving under the influence. Defendant filed a motion to suppress all evidence obtained during the search that followed the stop, claiming that the stop was illegal because it was not based upon probable cause that she had committed a traffic infraction. At issue was the application of the fellow officer rule to testimony in a motion to suppress hearing where defendant was challenging the validity of the traffic stop. The court held that the fellow officer rule did not allow an officer who did not have firsthand knowledge of the traffic stop and was not involved in the investigation at the time to testify as to hearsay regarding what the initial officer who conducted the stop told him or her for the purpose of proving a violation of the traffic law so as to establish the validity of the initial stop. Therefore, the court disapproved of the Fourth district in Ferrer v. State and approved the decision of the Second District in Bowers v. State. View "State v. Bowers" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death for his role in the 1987 killing of a correctional officer. Defendant subsequently appealed the circuit court's summary denial of his second successive motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.851. Because defendant's claim originated from information that existed as early as this court's issuance of its direct-appeal decision in 1990, and because the juror affidavits at issue in this case related to matters that inhered in the verdict, the court affirmed the circuit court's denial of this claim as both untimely and based upon inadmissible evidence. View "Van Poyck v. State" on Justia Law

This case was before the court on appeal from a judgment of conviction of first degree murder and a sentence of death. The court held that the trial court properly limited the cross-examination of a State witness; the trial court did not abuse its discretion in overruling defense counsel's objection and denying a mistrial based upon the prosecution's statement; the trial court did not abuse its discretion in admitting the 47 shell casings into evidence along with the other evidence to which they related; the trial court properly declined to conduct a Frye hearing on tool-mark identification; the trial court did not err in accepting the State's explanation for exercising a peremptory strike to remove a minority juror; and the death sentence was proportionate where, in addition to murdering the victim, defendant also kidnapped her from her home and raped her. Accordingly, the convictions and sentences were affirmed. View "King v. State" on Justia Law

Defendant, a prisoner under sentence of death, appealed the denial of his successive motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.851. Defendant asserted a destruction of evidence claim and Brady v. Maryland claim. The court affirmed the circuit court's denial of postconviction relief. Further, the court rejected the State's cross-appeal and affirmed the determination of the postconviction court that defendant's second claim satisfied the due diligence component of Rule 3.851(d)(2)(A). No motion for rehearing would be entertained by this court. The mandate should issue immediately. Defendant's request for a stay of execution was denied. View "Waterhouse v. State" on Justia Law

Defendant appealed his conviction for first degree murder and his sentence of death. Defendant claimed that the trial court erred by instructing the jury on finding the heinous, atrocious, or cruel (HAC) aggravator for the murder of the victim and that defendant's death sentence was disproportionate. The court held that the jury instruction on the aggravator was not error when the victim was attending a party, defendant stormed in and demanded money with the threat of firing his AK-47, shot the victim multiple times, and the victim eventually died from the gunshot wounds. The court also concluded that the trial court did not err in finding the HAC aggravator because it was supported by competent substantial evidence. Considering the circumstances, the aggravating and mitigating factors weighed by the trial court, and other cases with similar facts, the court concluded that defendant's death sentence was proportionate. Further, the competent substantial evidence presented at trial was sufficient to support defendant's conviction. Therefore, the judgment was affirmed. View "Hall v. State" on Justia Law

The North Port Road and Drainage District (NPRDD), a municipal dependent special district wholly contained within the City of North Port, levied non-ad valorem special assessments against nine parcels of real property owned by West Villages Improvement District, an independent special district of the State of Florida. The Second District held that NPRDD could not lawfully impose the special assessments on West Villages' real property without statutory authority. The court affirmed, but on the basis that NPRDD's home rule power under the Florida Constitution did not reach as far as it argued. Accordingly, because there was no way for West Villages to lawfully pay the special assessments, NPRDD's assessments fell within the limitations on home rule powers set forth in section 166.021(3), Florida Statutes. View "North Port Road And Drainage Dist., etc. v. West Villages Improvement Dist., etc." on Justia Law

Raymond Bright was convicted of two counts of first-degree premeditated murder and sentenced to death for the murders. The Supreme Court affirmed the convictions and sentences, holding (1) sufficient evidence existed in the record for the jury to convict Bright of first-degree premeditated murder; (2) the prosecutor did not improperly comment on Bright's right to remain silent, and the trial court did not abuse its discretion when it denied Bright's motion for a mistrial; (3) the trial court erred when it found and weighed as two separate aggravating circumstances Bright's prior felony conviction, but the improper double finding of the prior violent felony aggravating circumstance constituted harmless error; (4) the trial court did not abuse its discretion in finding and affording the aggravating circumstance that the murder was especially heinous, atrocious, or cruel, great weight; and (5) the sentences imposed by the trial court were proportionate. View "Bright v. State" on Justia Law

Codefendants, Christopher Johnson and James Mayfield, appealed their convictions of robbery with a firearm and carjacking. At issue was the interpretation of sections 27.511(8) and 27.5303(1)(a), Florida Statutes, and whether the Office of Criminal Conflict and Civil Regional Counsel (RCC) had standing to challenge a public defender's motion to withdraw. The court held that section 27.5303(1)(a) governed all public defender motions to withdraw based on conflict, both at the trial and appellate level and the court where the motion was filled was required to review such motions for sufficiency. The court also held that RCC did not have standing to challenge a public defender's good faith request to withdraw based on conflict. View "Johnson v. State" on Justia Law

Defendant, who was 25-years-old at the time of the crime, was convicted of the 1999 sexual battery and first-degree murder of an 18-year-old and sentenced to death. On direct appeal, the court affirmed the convictions and sentences. Defendant subsequently appealed the denial of his motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.851 and simultaneously petitioned the court for a writ of habeas corpus. The court agreed with defendant that trial counsel's performance in preparation for the penalty phase was deficient but, nevertheless, affirmed the postconviction court's denial of relief because the court concluded that defendant did not demonstrate prejudice. View "Douglas v. State; Douglas v.Tucker, etc." on Justia Law

This case involved questions of law regarding probation revocation for failure to pay future restitution. The court held that before a trial court could properly revoke probation and incarcerate a probationer for failure to pay, it must inquire into the probationer's ability to pay and determine whether the probationer had the ability to pay but willfully refused to do so. Under Florida law, the trial court must make its finding regarding whether the probationer willfully violated probation by the greater weight of the evidence. The court also held that an automatic revocation of probation without evidence presented as to ability to pay to support the trial court's finding of willfulness violated due process. Accordingly, the State must present sufficient evidence of willfulness, including that the probationer has, or has had, the ability to pay, in order to support the trial court's finding that the violation was willful. Once the State has done so, it was constitutional to then shift the burden to the probationer to prove inability to pay to essentially rebut the State's evidence of willfulness. However, while it was constitutional to place the burden on the probationer to prove inability to pay, the aspect of section 948.06(5), Florida Statutes, that required the probationer to prove inability to pay by the heightened standard of clear and convincing evidence was unconstitutional. View "Del Valle v. State" on Justia Law