Justia Florida Supreme Court Opinion Summaries

The Supreme Court quashed the decision of the Fourth District Court of Appeal ruling that a peremptory strike was constitutionally impermissible because it was based on the prospective juror's religion, holding that the issue of the constitutionality of a religion-based strike was not properly preserved in the trial court and that the district court erred in reversing on the basis of an unpreserved argument.The district court concluded that the trial court erred in allowing the peremptory strike of the prospective juror at issue, basing its decision in part on its conclusion that the strike involved an unconstitutional religious test. The Supreme Court quashed the decision below, holding that Defendant's religion-based objection to the strike was not properly preserved. View "State v. Pacchiana" on Justia Law

The Supreme Court approved a proposed amendment titled "Raising Florida's Minimum Wage" for placement on the ballot but refused to review a financial impact statement prepared by the Financial Impact Estimating Conference (FIEC), holding that this Court lacked jurisdiction to do so.The Attorney General of Florida petitioned the Supreme Court for an advisory opinion on the validity of a proposed citizen initiative amendment to the Florida Constitution requesting review of the compliance of the proposed amendment with constitutional and statutory requirements. The Attorney General further requested an opinion addressing the compliance of the corresponding financial impact statement with Fla. Stat. 100.371. The Supreme Court held (1) the initiative petition and proposed ballot title and summary for the proposed amendment met the legal requirements of Fla. Const. art. XI, 3 and Fla. Stat. 101.161(1); and (2) this Court does not have original jurisdiction to review financial impact statements. View "Advisory Opinion to the Attorney General Re Raising Florida's Minimum Wage" on Justia Law

The Supreme Court affirmed the denial of Sparre's postconviction motion to vacate his conviction of first-degree murder and sentence of death filed under Fla. R. Crim. P. 3.851 and denied his petition for writ of habeas corpus, holding that Sparre was not entitled to relief.As to Sparre's appeal from the denial of his postconviction motion, the Supreme Court held (1) trial counsel was not ineffective, despite two instances in which counsel was deficient; (2) the trial court properly denied Sparre's claim that the cumulative effect of trial counsel's errors entitled him to relief; and (3) Sparre's claims that the postconviction court erred in three other respects were without merit. As to Sparre's habeas petition, the Court held that Sparre was not entitled to relief on his claims of ineffective assistance of appellate counsel. View "Sparre v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying Defendant relief from his conviction and denied Defendant's habeas conviction, holding that Defendant was not entitled to relief.Defendant was found guilty of first-degree felony murder and robbery with a firearm or other deadly weapon. Defendant later moved for postconviction relief. The trial court vacated Defendant's death sentence and ordered a new penalty phase pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016). Defendant appealed the denial of his guilt phase claims and petitioned the Supreme Court for a writ of habeas corpus. In the appeal from the postconviction motion, the Supreme Court affirmed, holding that Defendant was not entitled to relief on his allegations of error. The Court then denied habeas relief, holding that appellate counsel was not ineffective on direct appeal. View "Jordan v. State" on Justia Law

The Supreme Court declined to answer a question certified by the Fourth District Court of Appeal regarding whether, under the Fourth Amendment, a warrantless blood draw of an unconscious person incapable of giving consent may be pursuant to Fla. Stat. 316.1932(1)(c) so that the unconscious person can be said to have "consented" to the blood draw, holding that this case fell squarely within the rule announced in Mitchell v. Wisconsin, 139 S. Ct. 2525 (2019).The Wisconsin Supreme Court analyzed the Fourth Amendment issue using the "consent" framework of the statute. During the pendency of this appeal the United States Supreme Court considered a materially indistinguishable issue relating to a similar Wisconsin statute and vacated the Wisconsin Supreme Court's decision. The Supreme Court declined to address the certified question as framed, applied Mitchell, vacated the Fourth District's decision, and remanded, holding that because this case fell within the rule announced in Mitchell, the warrantless blood draw was legal. View "McGraw v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying John Mack Sketo Calhoun's motion to vacate his conviction of first-degree murder filed under Fla. R. Crim. P. 3.851 and denied Calhoun's petition for a writ of habeas corpus, holding that Calhoun was not entitled to relief.Specifically, the Supreme Court held (1) as to Calhoun's postconviction appeal, the circuit court properly denied relief as to Calhoun's newly discovered evidence claim, trial counsel was not ineffective during the guilt phase, and none of Calhoun's remaining claims warranted relief; and (2) as to Calhoun's habeas petition, Calhoun failed to demonstrate that appellate counsel was ineffective on direct appeal. View "Calhoun v. State" on Justia Law

The Supreme Court affirmed the circuit court's summary denial of Appellant's second successive motion for postconviction relief, holding that the petition was both untimely and procedurally barred.Appellant was convicted of first-degree murder and sentenced to death. Several years later, Appellant filed his second successive motion for postconviction relief under Fla. R. Crim. P. 3.851, arguing that, in Buck v. Davis, 137 S. Ct. 759 (2017), the United States Supreme Court established a new fundamental constitutional right that the injection of racial bias and prejudice into a criminal trial constitutes per se ineffective assistance of counsel. Further, Appellant argued that this right applies to convictions and sentences, like his, that became final before Buck. The Supreme Court disagreed, holding (1) Appellant's motion was untimely because Buck did not establish a new right; and (2) because this Court previously addressed the arguments at issue and held that they did not warrant relief Appellant's motion was procedurally barred. View "Bell v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's successive motion for postconviction relief, holding that the circuit court properly denied relief.Appellant pleaded guilty to first-degree murder, sexual battery, and other crimes. The trial judge sentenced Appellant to death for the murder. The Supreme Court affirmed the convictions and sentences on direct appeal. Appellant later filed a successive postconviction motion under Fla. R. Crim. P. 3.851, arguing that his death sentence was unconstitutional under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 S. 3d 40 (Fla. 2016). The circuit court summarily denied the motion. The Supreme Court affirmed, holding that Appellant's claim was procedurally barred to the extent it was raised in his earlier postconviction appeal and, additionally, failed on the merits. View "Brant v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction and death sentence for first-degree murder, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Court held (1) the jury instructions during the penalty phase were sufficient; (2) the trial court did not err in admitting Defendant's letters to a predecessor judge and the elected state attorney; (3) the trial court's findings of the CCP aggravator were supported by competent, substantial evidence; (4) there was no error in the court's analysis of the prior violent felony aggravator; (5) the sentencing order was sufficient; (6) the evidence was sufficient to sustain the murder conviction; and (7) the death sentence was proportionate. View "Rogers v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court summarily denying Gary Ray Bowles' successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851 and denied Bowles' petition for a writ of habeas corpus and the motions to stay his execution, holding that Bowles was not entitled to relief.Bowles pleaded guilty to first-degree murder and was sentenced to death. In 2017, Bowles filed a successive postconviction motion, raising an intellectual disability claim for the first time. Bowles filed the final version of this motion after the governor signed his death warrant in 2019. The postconviction court denied the intellectual disability claim as untimely. Bowles appealed and also filed a habeas petition alleging that his execution would constitute cruel and unusual punishment. The Supreme Court affirmed the denial of postconviction relief and denied the habeas petition, holding (1) Bowles' intellectual disability claim was untimely; (2) the postconviction court did not abuse its discretion in denying Bowles' request for certain public records; and (3) because the United States Supreme Court has made clear that capital punishment does not constitute cruel and unusual punishment under the Eighth Amendment, this Court cannot invalidate Bowles' death sentence as cruel and unusual. View "Bowles v. State" on Justia Law