Justia Florida Supreme Court Opinion Summaries

This case was before the Court for review of the decision of the Second District Court of Appeal in Zeigler v. State. The district court certified that its decision was in direct conflict with the decision of the First District Court of Appeal in Montgomery v. State. The court held that the district court's reasoning in Zeigler was inconsistent with the court's reasoning in Montgomery and the court's conclusion that the use of the erroneous manslaughter by act instruction constituted fundamental error that required reversal of Montgomery's conviction for second-degree murder. Accordingly, the court accepted jurisdiction and granted the petition for review. View "Zeigler v. State" on Justia Law

Defendant was convicted of the 1990 murder of a convenience store clerk and was sentenced to death. Defendant appealed the postconviction court's order summarily denying his successive motion for postconviction relief, filed pursuant to Florida Rule of Criminal Procedure 3.851, which challenged his conviction on the basis that a newly discovered witness significantly impeached the testimony of the only witness who identified defendant as leaving the crime scene immediately after the murder. The court reversed and remanded the Giglio v. United States and Brady v. Maryland claims to the postconviction court for an evidentiary hearing but denied the newly discovered evidence claim where the information provided by the new witness was not of such a nature that it would probably produce an acquittal on retrial. View "Mungin v. State" on Justia Law

This case was before the court on direct appeal from a judgment of conviction of first-degree murder and a sentence of death where defendant's convictions were based on the 2008 killing of a 13-year-old girl. Defendant raised several issues on appeal and the court disposed of each issue. The court affirmed defendant's convictions for sexual battery involving great physical force, aggravated child abuse, and first-degree murder. The court also affirmed the sentence of death. View "Caylor v. State" on Justia Law

Petitioner, an inmate in state custody, filed a pro se petition for writ of habeas corpus with the court seeking relief from an allegedly illegal sentence. The court denied the petition by way of an unpublished order, determining that it raised a repetitive claim addressed in a previous petition filed with the court. The court held, however, that in disposing the petition, the court expressly retained jurisdiction to pursue possible sanctions against petitioner. The court took notice that petitioner had compiled a history of pro se filings that, like the instant petition, were devoid of merit or inappropriate for review in the court. Accordingly, the clerk of the court was instructed to reject any future pleadings, petitions, motions, documents, or other filings submitted by petitioner unless such filings were signed by a member in good standing with The Florida Bar. View "James v. Tucker, Etc." on Justia Law

Defendant, a prisoner under sentence of death, appealed the denial of his motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.851. In the instant appeal, defendant primarily criticized his counsel's performance at trial for failing to adequately challenge the State's circumstantial case. Defendant argued that counsel rendered ineffective assistance for stipulating to the fact that DNA matching the victim's DNA was derived from blood as opposed to some other source. Defendant also contended that counsel was ineffective for failing to retain and call an expert to challenge the State's scratch-marks expert. Defendant additionally challenged counsel's presentation of mental health mitigation during the penalty phase. After conducting an evidentiary hearing, the postconviction court denied relief on these claims, as well as summarily denying relief on defendant's challenge to the rules prohibiting juror interviews. The court affirmed the postconviction court's denial of all claims. View "Crain, Jr. v. State" on Justia Law

Petitioner was convicted of several crimes, including the kidnapping of his eleven-year-old son. At issue was whether a parent could lawfully be convicted of kidnapping his own child under section 787.01, Florida Statutes. The court held that the plain language of section 787.01 did not preclude a parent from being held criminally liable for kidnapping his or her own child. View "Davila v. State" on Justia Law

Defendant, a prisoner under sentence of death, appealed from a circuit court order denying postconviction relief in this capital case. At issue was the court's procedure regarding the issue of pro se representation by defendants in capital postconviction appeals. Based on its solemn duty to ensure that the death penalty was imposed in a fair, consistent, and reliable manner, as well as the court's administrative responsibility to work to minimize the delays inherent in the postconviction process, the court held that death-sentenced defendants could not appear pro se in postconviction appeals. Accordingly, defendant's motion to discharge counsel and appear pro se and appellate counsel's motion for leave to withdraw were denied. View "Gordon v. State" on Justia Law

Defendant shot and killed a convenience store clerk during a robbery and was subsequently tried and convicted of armed robbery and first degree murder. At issue was whether the facts supported the trail court's legal conclusion that defendant had established the first prong of the mental retardation standard, i.e. significantly subaverage general intellectual functioning. The court held that the circuit court erred as a matter of law in finding that defendant met the definition of mental retardation under Florida law and therefore vacated the circuit court's order granting defendant's postconviction motion. View "State v. Herring" on Justia Law

Defendant was convicted of two counts of first-degree murder for the stabbing deaths of his cousin's girlfriend and her four-year-old daughter. Defendant appealed his convictions and sentences of death. The court held that the trial court did not abuse its discretion in denying defendant's motion for mistrial and in finding no discovery violations. The court also held that there was no basis that would disqualify the jury from rendering a penalty recommendation. The court rejected defendant's challenge to the constitutionality of Florida's death sentencing scheme. The court further held that the record demonstrated that there was competent, substantial evidence to sustain defendant's convictions. The court finally held that based on the evidence set forth, the aggravators the trial court found, and the totality of the circumstances, defendant's death sentences were proportionate compared to other death sentences the court had upheld. Accordingly, the court affirmed the convictions and sentences. View "Knight v. State" on Justia Law

Defendant was convicted of the first-degree shooting murder of a deputy sheriff, the attempted murder of another deputy sheriff, and armed robbery. Defendant was sentenced to death. Both defendant and the State raised issues on appeal. The court held that the trial court did not abuse its discretion in admitting photographic evidence and a vial of blood; in admitting a bullet fragment into evidence; and in failing to instruct the jury that defendant was not guaranteed parole at or after 25 years. The court also held that, because defendant failed to demonstrate that any of his claims amounted to error, defendant's claim of cumulative error was denied. The court finally held that, when compared with other capital cases, the death sentence in defendant's case was proportionate. View "Armstrong v. State of Florida" on Justia Law