Justia Florida Supreme Court Opinion Summaries

Petitioner received a 30 year sentence for burglary, a 10 year sentence for auto theft, and a life sentence for kidnapping where petitioner's sentences stemmed from his theft of a vehicle in which a two-year-old child was asleep in the backseat. At issue was whether petitioner committed the additional crime of kidnapping if he did not know the child was in the backseat before or during his commission of the auto theft, which was the underlying felony used to support his kidnapping conviction. The court held that, because the State failed to produce sufficient evidence demonstrating petitioner's awareness of the victim before or during his execution of the underlying felony, critical statutory requirements for the kidnapping offense were not satisfied. Therefore, the district court's decision relying on the Faison v. State three-part test to affirm the trial court's denial of petitioner's motion for judgment of acquittal was erroneous.

Petitioner appealed the trial court's order denying his motion filed under Florida Rule of Criminal Procedure 3.851 to vacate his conviction of first degree murder and sentence of death. Petitioner raised numerous claims of trial court error, ineffective assistance of counsel, and habeas relief. The court held that the trial court properly determined that counsel was not ineffective for offering the testimony of petitioner's brother; petitioner failed to demonstrate that counsel was ineffective in presenting the mental health mitigation; the trial court properly denied petitioner's claim that counsel was ineffective in allowing the admission of petitioner's confession to a prior murder; the trial properly admitted evidence of petitioner's prior murder conviction; counsel was not ineffective for failing to move to suppress petitioner's statements of law enforcement; petitioner was not entitled to relief where counsel was ineffective for failing to inform the jury that petitioner was medicated during a prior, unrelated trial; counsel was not ineffective for failing to object to erroneous jury instructions; and the trial court did not err in summarily denying several of petitioner's claims. The court also held that petitioner was not entitled to habeas relief where all of his claims were either without merit or procedurally barred.

Respondent filed a petition for writ of habeas corpus alleging that he was entitled to immediate release where respondent's claim concerned the sentences that were imposed following his violation of probation. At issue was whether a court may sua sponte dismiss a petition for a writ of habeas corpus, in which a prisoner was seeking immediate release, based upon the petitioner's failure to allege exhaustion of administrative remedies. The court held that, in light of the constitutional and statutory authorities and precedent, the habeas petition could not be dismissed based upon the petitioner's failure to exhaust administrative remedies where such failure had not been raised by the parties.

Respondent appealed his sentence when he was convicted of aggravated battery with great bodily harm, permanent disability, or permanent disfigurement; shooting within a dwelling; and false imprisonment. At issue was whether, in cases in which convictions were final before Apprendi v. New Jersey was issued, Apprendi and Blakely v. Washington applied to resentencing proceedings held after Apprendi issued where the sentencing was not final when Blakely issued. The court held that Apprendi and Blakely applied to such resentencings conducted after Apprendi and Blakely issued where resentencing was a de novo proceeding in which the decisional law effective at the time of the resentencing applied.

The State charged Petitioner Clayton Harris with possession of pseudoephedrine with the intent to manufacture methamphetamine, in violation of state law. On a traffic stop, officers noticed that Petitioner was "shaking, breathing rapidly, and could not sit still." When Petitioner did not consent to a search of his vehicle, officers brought over their drug-sniffing dog to conduct a "free sniff" of the exterior of the vehicle. The dog alerted to the smell of drugs on the driver's side door. Using the alert as the basis of a warrantless search of the interior, officers discovered pseudoephedrine under the driver's seat and 8 boxes of matches. Petitioner was placed under arrest, and after being read his Miranda rights, stated that he had been cooking meth at least two weeks prior to this traffic stop. At trial, the State argued that the arresting officer had probable cause based on his observations from the stop: an expired plate-tag, Petitioner's nervousness, and an alert from a trained drug-sniffing dog. Petitioner challenged the dog's reliability. The trial court denied the motion to suppress, found that there was probable cause to search Petitioner's vehicle, and admitted all physical evidence seized. The Supreme Court granted discretionary review to resolve a conflict between the district courts on whether a drug-sniffing dog's alert to its handler can provide probable cause to conduct a warrantless search of the interior of a vehicle. The Court held that the dog's alert alone is not enough; the State must present evidence of the dog's training and certification records; the trial court must assess the reliability of the dog's detection. In this case, the Court reviewed the totality of the circumstances to find that the trial court should have granted Petitioner's motion to suppress; the Court remanded this case for further proceedings.

Respondent Enterprise Leasing Company leased a motor vehicle to Elizabeth Price for less than a year. Her son crashed the leased vehicle into a vehicle owned by Petitioner Rafael Vargas. Vargas filed suit against Price and Enterprise. The only count of the complaint directed at Enterprise claimed that the company was vicariously liable as the owner of the vehicle, pursuant to state law section 324.021(9)(b)2. Vargas did not contend that Enterprise was negligent, that its lease to Price was improper, or that it was in any way at fault for the accident. Enterprise filed an Answer and affirmative defenses, asserting that pursuant to 49 U.S.C. §30106, or the "Graves Amendment," it had no liability. The circuit court granted Enterprise's motion for summary judgment, ruling that the Graves Amendment preempted state law, holding that the state law was a vicarious liability provision and not a financial responsibility one. The court entered a final judgment consistent with Enterprise's consent to judgment, and Vargas appealed. The appellate court affirmed the lower court's decision and held one issue for review by the Supreme Court: whether the Graves Amendment as enacted by Congress preempted state law involving short term leases of motor vehicles. Florida had eliminated vicarious liability for a certain category of owner/lessors; Congress, through the Graves Amendment, sought to eliminate vicarious liability for that category of owners/lessors in which the state law left exposed to liability. On analysis, the Supreme Court found that the savings clause of the Graves Amendment does not supersede state laws that impose financial responsibility on the owner of a vehicle or that impose liability on businesses who rent or lease vehicles for failure to meet financial responsibility requirements under state law, and affirmed the decision of the circuit court.

The Court considered whether a "sniff test" by a drug detection dog conducted at the front door of a private residence is a "search" under the Fourth Amendment, and if so, whether the evidentiary showing of wrongdoing that the government must make prior to conducting such a search is probable cause or reasonable suspicion. A Crimestoppers tip alerted police to a private home where drugs were suspected; officers arrived at the house with a drug detection dog. The dog alerted to the scent of marijuana, and on approaching the house, police then smelled the scent. The magistrate supressed the evidence seized at the home, and the State appealed. Petitioner Jardines sought review by the Court on a certified question that conflicted with state law pertaining to whether the "sniff test" was a violation of his constitutional rights. Concluding that the dog "sniff test" conducted here was an intrusive procedure because it took place in the home, the Court held that results of the "sniff test" were properly withheld from the magistrate's probable cause determination.