Justia Florida Supreme Court Opinion Summaries

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

Defendant appealed from the denial of his claims of ineffective assistance of counsel and fundamental error with respect to the admission of a 45-caliber revolver. The Fourth District held that the trial court properly admitted the revolver, which was recovered from defendant when he was arrested five years after the murder - even though the revolver was indisputably not connected to the crime. The Fourth District concluded that because the revolver was properly admitted, both defendant's ineffective assistance of counsel claim and his fundamental error claim failed. The court held that the Fourth District erred in holding that a gun unrelated to the crime was admissible where the purported relevancy was outweighed by the danger of confusing the issues and misleading the jury. The court also held that the district court erred in admitting the bandana and latex gloves. Accordingly, the court quashed the Fourth District's decision and approved the Fifth District's decision in Moore v. State. View "Agatheas v. State" on Justia Law

This case involved two certified questions related to the Jimmy Ryce Act, Sections 394.910-.932, Florida Statutes. The court held that a Jimmy Ryce respondent who had unsuccessfully objected to a continuance or filed a motion to dismiss in the trial court could challenge a violation of the thirty-day statutory time limit by way of filing a petition for writ of habeas corpus prior to trial or could choose to wait until the conclusion of trial to bring the challenge on direct appeal. The court also held that should respondent wait until after the trial to issue this challenge, he or she must demonstrate an impact on the fairness of the trial to be entitled relief. Therefore, the court held that defendant did not waive his claim by waiting to bring it until after the trial, he was not entitled to release and dismissal of the Jimmy Ryce proceedings because he was challenging the length of his pretrial detention and not alleging that the improper continuance had any impact on the fairness of his trial. View "Boatman v. State" on Justia Law

Defendant, a prisoner under sentence of death, appealed an order of the circuit court denying his initial motion under Florida Rule of Criminal Procedure 3.851 to vacate his conviction of first-degree murder and sentence of death and petitioned the court for a writ of habeas corpus. On appeal, defendant raised the following claims: (A) trial counsel was ineffective for failing to develop and present mitigation; (B) trial counsel was ineffective for failing to file a motion to suppress his confession; (C) trial counsel was ineffective for failing to have the jury view the entire confession tape; (D) trial counsel was ineffective in the guilt phase; (E) the postconviction court violated defendant's right to due process by summarily denying several claims; (F) the postconviction court erred in denying claims regarding the testimony of the fingerprint examiner; (G) the postconviction court erred in denying defendant's claim that the State committed a Brady violation by not conducting promised blood testing; (H) cumulative error deprived defendant of a fair trial; and (I) defendant may be incompetent to be executed. The court addressed each claim and subsequently affirmed the postconviction court's order denying relief and denied the habeas petition. View "Buzia v. State; Buzia v. Tucker, etc." on Justia Law

Defendant was convicted and sentenced to death for murder. Defendant subsequently appealed the denial of his motion for postconviction relief under Florida Rule of Criminal Procedure 3.851. Defendant claimed that his counsel rendered ineffective assistance in the penalty phase, that the State withheld favorable information, that the State made a false statement during trial, and that the postconviction court erred during the evidentiary hearing. The court concluded that defendant's counsel was deficient for stipulating to the admissibility of a statement defendant made to law enforcement on May 7, 1982. The court also concluded that the State withheld favorable information, specifically the complete terms of a cooperation agreement with a codefendant. The court concluded, however, that because defendant failed to demonstrate prejudice on these claims and his remaining claims were without merit, the judgment was affirmed. View "Parker v. State" on Justia Law

Defendant was convicted on three counts of first-degree murder and sentenced to death on each count. Defendant appealed an order denying a second successive motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, claiming that he was deprived of effective trial counsel during the penalty phase because that phase was conducted before a jury that returned a death recommendation in violation of Porter v. McCollum. The court held that the trial level postconviction court properly denied defendant's second successive postconviction motion because the decision in Porter did not constitute a fundamental change in the law that mandated retroactive application under Witt v. State. Therefore, the court affirmed the judgment. View "Walton v. State" on Justia Law