Justia Florida Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed the order of the circuit court denying Appellant's successive postconviction motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to postconviction relief. In 1993, Appellant's two death sentences became final. In his postconviction motion Appellant raised claims predicated on the United States Supreme Court's decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and the Supreme Court's decision on remand in Hurst v. State, 202 So. 3d 40 (Fla. 2016). The circuit court denied the motion. The Supreme Court affirmed, holding that this Court's precedent and the United States Supreme Court's precedent foreclosed relief as to Appellant's claims. View "Ponticelli v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's death sentences that were imposed after a second penalty phase, holding that there was no error or abuse of discretion. Defendant was convicted of two counts of first-degree murder and sentenced to death for each murder. The trial court granted a new penalty phase during postconviction proceedings on the grounds that counsel rendered ineffective assistance. After a second penalty phase, a death sentence was again imposed for each murder. The Supreme Court affirmed, holding (1) the trial court did not err by failing to instruct the jury that it must determine beyond a reasonable doubt whether the aggravators were sufficient to impose death and outweighed the mitigators; (2) none of the prosecutor's allegedly improper comments during closing argument rose to the level of fundamental error; (3) competent, substantial evidence supported the finding of the especially heinous, atrocious, or cruel aggravator; (4) the trial court did not abuse its discretion in rejecting two statutory mitigating circumstances presented with respect to both errors; and (5) the sentences of death were proportionate. View "Bright v. State" on Justia Law

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The Supreme Court affirmed the order of the trial court denying Appellant's successive postconviction motion filed pursuant to Fla. R. Crim. P. 3.851 seeking relief from his sentence of death pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016), holding that State v. Poole, 45 Fla. L. Weekly S41 (Fla. Jan. 23, 2020), was dispositive in this case. Appellant's death sentence became final in 1990, before the Supreme Court decided Ring v. Arizona, 536 U.S. 584 (2002). The Supreme Court subsequently decided Poole, pursuant to which there was no Hurst error in Appellant's case because a unanimous jury finding establishes the existence of at least one statutory aggravating circumstance beyond a reasonable doubt. In the instant case, the Supreme Court held that two of the four statutory aggravating circumstances found by the trial court - that the capital felony was committed during the commission of a sexual battery and for pecuniary gain - were established because Appellant's jury found him guilty of the contemporaneous crimes of sexual battery and robbery. View "Reed v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the trial court summarily denying Appellant's successive motion for post conviction relief pursuant to Fla. R. Crim. P. 3.851 and, alternatively, to correct an illegal sentence pursuant to Fla. R. Crim. P. 3.800(a), holding that there was no error in the trial court's summary denial of relief. In his postconviction relief motion, Appellant sought relief from his sentence of death, raising claims predicated on Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 S. 3d 40 (Fla. 2016). The trial court summarily denied relief. The Supreme Court affirmed, holding that Appellant's claims were procedurally barred, and even without the procedural bar, this Court's recent decision in State v. Poole, 45 Fla. L. Weekly S41 (Fla. Jan. 23, 2020), foreclosed relief. View "Boyd v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed an order denying in part and dismissing in part Hector Sanchez-Torres's third amended motion filed under Fla. R. Crim. P. 3.851 to vacate judgments of conviction and sentence of death and denied Appellant's petition for habeas relief, holding that Sanchez-Torres was not entitled to relief on any of his claims. Sanchez-Torres pled guilty to armed robbery and first-degree murder. The trial court sentenced Sanchez-Torres to death. The Supreme Court affirmed. Sanchez-Torres then filed a motion to vacate his judgments of conviction and sentence. The postconviction court denied some of his claims and dismissed the others. Sanchez-Torres appealed and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court denied relief, holding (1) the postconviction court did not err in denying Sanchez-Torres's claims; and (2) Sanchez-Torres's claims of ineffective assistance of trial counsel and appellate counsel did not warrant habeas corpus relief. View "Sanchez-Torres v. State" on Justia Law

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The Supreme Court approved the court of appeal's decision to uphold Defendant's sentence and disapproved of several recent court decisions to the extent they held that resentencing is required for all juvenile offenders serving a sentence longer than twenty years without the opportunity for early release based on demonstrated maturity and rehabilitation, holding that Defendant in this case did not establish a violation of Miller v. Alabama, 567 U.S. 460 (2012). Defendant was charged with the first-degree murder of her mother committed when she was age seventeen. Defendant pled guilty to second-degree murder in exchange for a forty-year sentence. Defendant later challenged her sentence as cruel and unusual punishment under Miller. The trial court denied Defendant's petition. The court of appeal affirmed but certified conflict with several decisions of other district courts. The Supreme Court affirmed, holding that because Defendant did not establish that her sentence was a life sentence or the functional equivalent of a life sentence Defendant failed to establish that her sentence violated the Eighth Amendment, Miller, or its equivalent on a juvenile homicide offender whose youth has not been taken into account at sentencing. View "Pedroza v. State" on Justia Law

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The Supreme Court affirmed the order of the post conviction court denying Appellant's motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the postconviction court properly denied all claims argued in this appeal. In his postconviction motion Defendant raised several ineffective assistance of counsel claims, as well as a claim alleging retroactive application of Riley v. California, 573 U.S. 373 (2014). The postconviction court entered an amended order denying relief on all claims. The Supreme Court affirmed, holding (1) the alleged failures on the part of defense counsel did not rise to the level of ineffective assistance of counsel; and (2) Defendant's claim that he was entitled to a new trial under Riley was procedurally barred because Defendant failed to raise this claim on direct appeal. View "Smith v. State" on Justia Law

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The Supreme Court approved the First District Court of Appeal's decision affirming Defendant's felony conviction for aggravated assault with a deadly weapon, an automobile, and rejecting Defendant's argument that his jury should have been instructed on reckless driving as a lesser-included offense, holding that Defendant was not entitled to his requested jury instruction on the permissive lesser-included offense of reckless driving where the charging instrument failed expressly to allege the element of driving. The First District affirmed Defendant's conviction and sentence on the ground that reckless driving is not a permissive lesser-included offense of aggravated assault with a deadly weapon, an automobile unless the charging instrument alleged that the defendant was driving at the time of the offense. On appeal, Defendant argued that the information alleged use of an automobile to commit the offense and that it was undisputed that he was driving at the time of the offense, entitling him to a jury instruction on the charge of reckless driving as a permissive lesser-included offense. The Supreme Court affirmed, holding that an element of an offense cannot be established in a charging document by inference, and the charging instrument in this case failed expressly to allege the element of driving. View "Anderson v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the post conviction court summarily denying Defendant's eighth successive motion to vacate his judgment of conviction and sentence, holding that all of Defendant's postconviction claims were legally insufficient or based on allegations that were conclusively refuted by the record. Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed. This case concerned Defendant's eighth successive motion to vacate the judgment of conviction and sentence. Along with his eighth successive motion Defendant filed a motion to compel discovery documents from the Office of the State Attorney. The postconviction court summarily denied Defendant's eighth successive postconviction motion and denied his motion to compel. The Supreme Court affirmed, holding (1) Defendant was not entitled to an evidentiary hearing on a newly discovered evidence claim alleging spoliation of evidence and a Brady violation; (2) Defendant was not entitled to an evidentiary hearing on his ineffective assistance of counsel claims; (3) the trial court did not err in summarily denying a standalone actual innocence claim; and (4) because Defendant failed to demonstrate his entitlement to the requested records the postconviction court correctly denied his motion to compel. View "Sweet v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying in part Marvin Cannon's initial postconviction motion filed pursuant to Fla. R. Crim. P. 3.851 and denied Cannon's petition for writ of habeas corpus, holding that Cannon was not entitled to relief on his claims. Cannon was convicted of first-degree murder and other crimes and sentenced to death. Cannon later filed his initial motion for postconviction relief, asserting that he was entitled to resentencing under Hurst v. State, 202 So. 3d 40 (Fla. 2016), that counsel was ineffective, and that the Department of Corrections' website reflected he was still serving a fifteen-year sentence for attempted robbery even though that conviction was vacated on direct appeal. The trial court agreed with Cannon's Hurst claim and vacated his death sentence but denied the remaining claims. The Supreme Court affirmed, holding that Cannon was not denied constitutionally effective assistance of counsel and that the postconviction court properly denied Cannon's second claim. In his habeas petition, Cannon alleged ineffective assistance of appellate counsel. The Supreme Court denied the petition, holding that appellate counsel was not ineffective for failing to raise a procedurally barred claim. View "Cannon v. State" on Justia Law