Justia Florida Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court quashed the decision of the Fifth District Court of Appeal concluding that the circuit court lacked jurisdiction to impose a sexual predator designation on an offender who qualified under the Florida Sexual Predators Act, Fla. Stat. 775.21, when the sentencing court did not impose the designation at sentencing and the offender's sentence had been completed, holding that the Fifth District erred.In 2009, Defendant was sentenced to six months' incarceration, followed by two years of sex offender community control, followed by three years of sex offender probation. In 2015, Defendant completed all portions of his sentence. In 2018, the State filed a notice stating that Defendant's original offense was an enumerated offense under section 775.21, thus obligating the trial court to designate Defendant as a sexual predator. The trial court determined that Defendant must comply with the registration requirements because section 775.21 placed an obligation on the court to designate Defendant as a sexual predator. The Fifth District reversed. The Supreme Court reversed, holding that section 775.21 confers jurisdiction on a trial court to designate a sexual predator after he is sentenced and completes his probation. View "State v. McKenzie" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's judgments of conviction of first-degree murder and sentences of death, holding that there was no prejudicial error in the proceedings below.Defendant was convicted and sentenced to death for his role in a 2016 triple homicide. The Supreme Court affirmed the convictions and sentences, holding (1) certain prosecutorial comments challenged by Defendant did not constitute fundamental error; (2) the trial court did not err in permitting the use of a map as a demonstrative aid; (3) there was no error in the State's presentation of victim impact evidence; and (4) the evidence was sufficient to support the convictions. View "Alcegaire v. State" on Justia Law

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The Supreme Court approved the decision of the First District Court of Appeal affirming Defendant's conviction of of three counts of sexual battery and one count of lewd or lascivious exhibition, holding that the schedule of lesser included offenses promulgated by the Florida Supreme Court in 2018 incorrectly classified sexual battery as a necessarily lesser included offense of capital sexual battery.On appeal, Defendant argued that the trial court erred in denying his motion to instruct the jury on sexual battery as a category one, necessarily lesser included offense of capital sexual battery. The First District affirmed. The Supreme Court affirmed, holding that sexual battery is not a necessarily lesser included offense of capital sexual battery. View "Allen v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the trial court denying Defendant's claims that he was intellectually disabled and therefore ineligible for the death penalty and that he was entitled to relief under Hurst v. Florida, 577 U.S. 92 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016), holding that there was no error.Defendant was convicted and sentenced in death in 1985 for first-degree murder. Before the Supreme Court in this case was Defendant's successive motion under Fla. R. Crim. P. 3.203 raising an intellectual disability claim. The trial court denied the claim, concluding that Defendant had not established intellectual disability and that Defendant was not entitled to relief under Hurst. The Supreme Court affirmed, holding that Defendant failed to establish that he was entitled to relief. View "Nixon v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the court of appeal that invited error precluded review of Defendant's claim on appeal that a jury charge was coercive, holding that the court of appeal did not err.Defendant was convicted of manslaughter with a deadly weapon, two counts of attempted manslaughter, and unlawful possession of a firearm by a minor. Defendant appealed, arguing that the jury's verdict was coerced by the trial court's issuance of a second modified Allen charge, which defense counsel requested. The court of appeal affirmed, concluding that although the charge was coercive, Defendant waived the error by agreeing to the modified charge. The Supreme Court affirmed, holding that the invited error precluded review for fundamental error. View "Baptiste v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the postconviction court denying Gary Hilton's motion to vacate his conviction of first-degree murder and sentence of death and denied Hilton's petition for a writ of habeas corpus, holding that Hilton was not entitled to relief.Specifically, the Supreme Court held (1) as to Hilton's claims of ineffective assistance of counsel, Defendant's allegations of deficient performance were insufficient to satisfy Strickland, and the postconviction court did not err in denying Hilton's claim that he was entitled to relief under Hurst v. Florida, 577 U.S. 92 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016); and (2) as to Hilton's petition for writ of habeas corpus, some claims were procedurally barred and, as to his remaining claims, Hilton was not entitled to relief. View "Hilton v. State" on Justia Law

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The Supreme Court affirmed Defendant's judgment of conviction of first-degree murder and sentence of death, holding that Defendant failed to demonstrate error on the part of the trial court.Specifically, the Supreme Court held (1) the trial court did not commit fundamental error by failing to find beyond a reasonable doubt that sufficient aggravating circumstances existed and that those circumstances outweighed the mitigating circumstances; (2) there was no merit to Defendant's challenges to the trial court's handling of mitigating evidence; (3) Defendant's challenge to the constitutionality of the prior-violent-felony aggravator was unavailing; and (4) Defendant's guilty plea was voluntarily and knowingly given. View "Davidson v. State" on Justia Law

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The Supreme Court affirmed the order of the trial court summarily dismissing Defendant's successive motion for postconviction relief, holding that the trial court did not err.Defendant pleaded guilty to two counts of first-degree murder and was sentenced to death. The Supreme Court affirmed on direct appeal. When his convictions and sentences had been final for more than twenty-three years Defendant filed the instant successive postconviction motion under Fla. R. Crim. P. 3.851, raising five claims. The trial court summarily dismissed the successive motion. The Supreme Court affirmed, holding (1) the trial court did not err in dismissing four of Defendant's claims as untimely; and (2) Defendant's claim that his death sentences violated the Sixth and Fourteenth Amendments in light of Hurst v. Florida, 577 U.S. 92 (2016), was both untimely and without merit. View "James v. State" on Justia Law

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The Supreme Court affirmed Defendant's convictions for first-degree murder but reversed his sentence of death and remanded for the limited purpose of resentencing and a new sentencing order, holding that the trial court improperly relied on facts not in the record in sentencing Defendant to death.Specifically, the Supreme Court held (1) the trial court impermissibly relied on non record evidence from the trial of Defendant's codefendant in finding that Defendant was the shooter in this case and sentencing him to death; and (2) Defendant was not entitled to relief on his remaining claims of error. The Supreme Court remanded the case for the limited purpose of requiring the trial court to perform a new sentencing evaluation and provide a new sentencing order. View "Cruz v. State" on Justia Law

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The Supreme Court quashed the decision of the Fourth District Court of Appeal in this juvenile sentencing case remanding for the trial judge to remedy a harmful Alleyne error through a "ministerial correction" of sentence for which the defendant "need not be present," holding that the remedy fell short of the de novo sentencing required by Williams v. State, 242 So. 3d 280 (Fla. 2018).At issue was the proper remedy for a harmful Alleyne error that occurs where, in sentencing a juvenile offender under Fla. Stat. 775.082(1)(b), the trial court enhances the sentence without a jury finding of the fact that authorizes the enhancement. In this case, Defendant, who committed two homicides, argued that he should be resentenced because the jury was not asked to find, and did not find, that he "actually killed, attempted to kill, or intended to kill the victims," as required under section 775.082(1)(b)1. The Fourth District concluded that the trial court committed a harmful Alleyne error in resentencing Defendant and remanded for "ministerial correction" of Defendant's sentences, for which Defendant "need not be present[.]" The Supreme Court quashed the Fourth District's decision, holding that Defendant was entitled to the de novo resentencing required by Williams. View "Puzio v. State" on Justia Law