Justia Florida Supreme Court Opinion Summaries

Twenty-six Florida counties and the Florida Association of Counties filed suit seeking a declaratory judgment that section 19 of the Laws of Florida (Act) was unconstitutional. The district court affirmed the trial court's decision and held that section 19 of the Act unconstitutionally shifted the responsibility to fund certain costs of court-appointed counsel from the state to the counties in violation of article V, section 14, of the Florida Constitution and that section 19 was unconstitutional based on the Legislature's failure to make the constitutionally required determination of an important state interest, as provided by article VII, section 18(a) of the constitution. The court agreed with the district court and the circuit court that the plain language of article V, section 14 provided that the state was responsible for funding the Offices of Criminal Conflict and Civil Regional Counsel (RCC), including the overhead costs outlined in subsection (c). The court held that, based on its determination that the district court correctly held that section 19 was unconstitutional under article V, section 14, the court concluded that it was unnecessary to address whether section 19 violated article VII, section 18(a) of the constitution. View "Lewis, et al. v. Leon County, et al." on Justia Law

Defendant appealed his conviction of first-degree murder and sentence of death. The court held that the trial court did not abuse its discretion in accepting defendant's request to waive the presentation of mitigation during the penalty phase where the trial court complied with the three-part procedure in Koon v. Dugger and complied with the Muhammad v. State requirements. The court also affirmed the trial courts finding of cold, calculated, and premeditated (CCP) and especially heinous, atrocious, or cruel (HAC) aggravators. The court court further held that because the trial court did not abuse its discretion, the court would not reweigh the trial court's assignment of weight. Therefore, the court held that defendant's death sentence was proportionate. The court finally held that a review of the record revealed that defendant's plea was made knowingly, intelligently and voluntarily. Therefore, the plea and conviction were properly entered. Further, the factual basis for the plea, which was confirmed by defense counsel and defendant, and was proven by the forensic evidence and defendant's confessions, provided competent, substantial evidence to support the conviction and sentence. View "Russ v. State of Florida" on Justia Law

Defendant was convicted of trafficking in cocaine and sale or possession of cocaine within 1000 feet of a church. At issue was whether the trial judge's arbitrary policy of rounding up sentences constituted a due process violation that was fundamental error reviewable on appeal without contemporaneous objection. The court held that the sentence imposed was within the legal guidelines - it was above the minimum required by the scoresheet and below the statutory maximum, but the trial judge's stated policy "improperly extended" defendant's incarceration in an arbitrary manner. Therefore, because this policy of "rounding up" violated defendant's right to due process, the court quashed the decision and remanded with directions that the trial court be directed to enter a sentence at the bottom of the guidelines and consistent with the reasoning expressed. View "Cromartie v. State of Florida" on Justia Law

Appellant, a prisoner under sentence of death, appealed the denial of his amended successive motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.851. Defendant raised numerous claims, including an Eighth Amendment challenge to the Florida Department of Correction's (DOC) lethal injection protocol, which replaced the first drug in its three-drug sequence, sodium thiopental, with another drug, pentobarbital sodium. The court held that, after reviewing the evidence and testimony, appellant had failed to satisfy the "heavy burden" that Florida's current lethal injection procedures, as implemented by the DOC, were constitutionally defective in violation of the Eighth Amendment. The court affirmed the circuit court's orders and vacated the temporary stay on execution. View "Valle v. State of Florida" on Justia Law

This case was before the court on the petition of Rosalie Whiley for a writ of quo warranto seeking an order directing the Governor of the State of Florida to demonstrate that he had not exceeded his authority, in part, by suspending rulemaking through Executive Order 11-01. The court granted relief and held that the Governor impermissibly suspended agency rulemaking to the extent that Executive Orders 11-01 and 11-72 included a requirement that the Office of Fiscal Accountability and Regulatory Reform (OFARR) must first permit an agency to engage in the rulemaking which had been delegated by the Florida Legislature. Absent an amendment to the Administrative Procedure Act, 5 U.S.C. 500 et seq., itself or other delegation of such authority to the Governor's office by the Florida Legislature, the Governor had overstepped his constitutional authority and violated the separation of powers. View "Whiley v. Hon. Rick Scott, etc." on Justia Law

Plaintiffs in these cases filed actions based on various degrees of asbestosis. According to plaintiffs, when they filed their lawsuits before the adoption of the Asbestos and Silica Compensation Fairness Act (Act), Chapter 774, Part II, Florida Statutes, it was not necessary to establish that any malignancy or physical impairment had already resulted from their contraction of asbestosis. Instead, plaintiffs claimed that it was merely necessary to show that they had suffered an injury from an asbestos-related disease. At issue was whether the Act could be retroactively applied to prejudice or defeat causes of action already accrued and in litigation. The court held that, based upon well-established common law precedent, plaintiffs had an accrued cause of action for the injuries they allegedly sustained due to asbestos exposure, and these causes of action constituted a property interest in which plaintiffs had a vested right under article I, section 2 of the Florida Constitution. The court also held that retroactive application of the Act here would operate to completely abolish plaintiffs' vested rights in accrued causes of action for asbestos-related injury. Therefore, the court held that the Act could not be constitutionally applied to plaintiffs. View "American Optical Corp., et al. v. Spiewak, et al.; American Optical Corp., et al. v. Williams, et al." on Justia Law

This case stemmed from respondent's agreement to lease an airplane from Aerolease of America, Inc. (Aerolease) and the subsequent plane crashed that occurred, which killed the pilot and his passenger. Petitioner, in his capacity as administrator ad litem and personal representative of the passenger's estate, filed a wrongful death action against Aerolease. At issue was whether the federal law currently codified at 49 U.S.C. 44112 preempted Florida state law with regard to the liability of aircraft owners under the dangerous instrumentality doctrine and, if it did, how broadly the scope of that preemption covered. The court held that the dangerous instrumentality doctrine imposed vicarious liability upon owners and lessors of aircraft, even where the aircraft was not within their immediate control or possession at the time of the loss. To the extent that the doctrine applied to injuries, damages, or deaths that occurred on the surface of the earth, the doctrine conflicted with, and was therefore preempted by, section 44112. However, because the death of the passenger occurred while he was a passenger in a plane that crashed, not on the ground beneath the plane, the wrongful death action filed by petitioner was not preempted by section 44112. Therefore, the dangerous instrumentality doctrine applied and the Second District erroneously affirmed the summary final judgment entered by the trial court in favor of Aerolease on the basis of federal preemption. View "Vreeland, etc. v. Ferrer, etc., et al." on Justia Law

Defendant was convicted of first degree murder, both premeditated and felony murder, as well as other felony counts, and sentenced to death. On instant appeal, defendant raised claims of ineffective assistance of trial counsel pertaining to both the guilt and penalty phase of trial and raised a claim arising after the court's remand to the circuit court, challenging the fairness of the postconviction evidentiary hearing based upon the denial of his motion to disqualify the circuit judge and the exclusion of certain testimony and evidence at the hearing. The court discussed each claim and held that the circuit court's order denying defendant's Florida Rule of Criminal Procedure 3.851 amended motion was affirmed. View "Mendoza v. State" on Justia Law

Defendant appealed the denial of his amended and supplemental motions for postconviction relief and petitioned for writ of habeas corpus where he was convicted of first degree murders and sentenced to death for the commission of a triple homicide. Defendant raised numerous claims before the court on appeal but focused primarily on two of those claims: whether the state presented expert testimony on comparative bullet lead analysis (CBLA), which evidence had now established was no longer a reliable science, and whether newly discovered evidence showed that a critical state witness testified untruthfully. The court held that the 2008 letter at issue clearly qualified as newly discovered evidence; thus, the postconviction court erred in finding that the claim was procedurally barred and that the letter did not constitute newly discovered evidence. Regardless of these errors, the court affirmed the postconviction court's denial of relief because defendant could not demonstrate that consideration of the letter would probably produce an acquittal on retrial under the newly discovered evidence standard. The court also held that, as to the Brady v. Maryland and Giglio v. United States claims, there was no basis for concluding that the state withheld favorable evidence under Brady or knowingly presented evidence at the original trial under Giglio. After the FBI discovered the errors in the original CBLA evidence introduced at trial, defendant was made aware of these errors by letter. The court rejected defendant's ineffectiveness claim because the record showed that trial counsel retained an independent expert to evaluate the FBI's CBLA and the expert provided counsel with no basis to challenge that analysis. Therefore, the court affirmed the postconviction court's denial of relief and also denied defendant's habeas petition. View "Wyatt v. State; Wyatt v. Buss" on Justia Law

Defendant appealed from a judgment of conviction of first degree murder and a sentence of death. Defendant was also convicted of home invasion robbery with a firearm, kidnapping, and aggravated fleeing and eluding a law enforcement officer. Defendant raised various issues on appeal regarding his post-arrest interrogation; letter of apology; victim impact statements; how the murder was committed in a cold, calculated, and premeditated manner; how the murder was especially heinous, atrocious, or cruel; proportionality of the sentence; Ring v. Arizona; and sufficiency of the evidence. The court addressed each of defendant's claims and held that the convictions and sentences were affirmed. View "Baker v. State" on Justia Law