Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's sentences of death imposed in connection with his conviction for two counts of first-degree murder, holding that Defendant was not entitled to relief on his claims of error.After he was originally convicted and sentenced Defendant received a new penalty phase in light of Hurst v. State, 202 So. 3d 40 (Fla. 2016). Thereafter, Defendant was resentenced to death for both murders. The Supreme Court affirmed Defendant's sentences of death, holding (1) Defendant's jury unanimously found that each of five aggravating factors was proven beyond a reasonable doubt; (2) there was no error in allowing the State to amend its notice of aggravating factors; (3) the trial court did not err in permitting the introduction of victim impact evidence; and (4) Defendant was not entitled to relief on his remaining claims of error. View "McKenzie v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court summarily denying Appellant's sixth successive motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, holding that the trial court did not err in summarily denying Appellant's postconviction motion.Appellant was convicted of first-degree murder, sexual battery, and burglary. The trial judge sentenced Appellant to death. In his sixth successive postconviction motion Appellant asserted two claims, including a claim under Brady v. Maryland, 373 U.S. 83 (1963). The trial court rejected both claims. The Supreme Court affirmed, holding that the trial court did not err in summarily denying Appellant's sixth postconviction motion. View "Booker v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and his sentence of death, holding that there was no error in the proceedings below.Defendant entered a no contest plea to first-degree murder, attempted murder of a correctional officer with a deadly weapon, and other crimes. The trial court sentenced Defendant to death. The Supreme Court affirmed the convictions and sentences, holding (1) the trial court did not abuse its discretion by not employing all of the mitigation-investigation procedures required in Muhammad v. State, 782 So. 2d 343 (Fla. 2001), because Muhammad's investigative procedures did not apply; (2) Defendant's second assignment of error was without merit; and (3) Defendant voluntarily and knowingly entered his no contest plea. 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 filed pursuant to Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief.Appellant was convicted of first-degree murder. In a seven-to-five vote recommendation the jury sentenced Appellant to death, and the death sentence became final in 1989. In his postconviction motion, Appellant argued that he was entitled to retroactive application of the Supreme Court's decision in State v. Poole, 297 So. 3d 487 (Fla. 2020), which receded from Hurst v. State, 202 So. 3d 40 (Fla. 2016) except as to the requirement that a jury must unanimously find the existence of a statutory aggravating circumstance beyond a reasonable doubt. The Supreme Court denied relief, holding that Poole did not retroactively apply to Appellant. View "Jackson v. State" on Justia Law

The Supreme Court reversed Defendant's convictions for first-degree murder and sentences of death, holding that the introduction of the testimony of Defendant's mother constituted harmful error.During Defendant's trial, Defendant's mother, Jeanne Avsenew, testified regarding multiple incriminating statements made and actions taken by Defendant shortly after the murders. At issue was whether the perpetuated testimony testimony of Jeanne, which was given despite her inability to see Defendant during her testimony, violated Fla. R. Crim. P. 3.190(i)(3), which requires that the defendant be in the witness's presence during testimony. The Supreme Court reversed, holding (1) the failure to ensure that Defendant was kept in the presence of his mother during her testimony constituted a clear violation of Rule 3.190(i)(3); and (2) the error was not harmless. View "Avsenew v. State" on Justia Law

The Supreme Court vacated Defendant's convictions for first-degree murder and remanded this case to the trial court for a new trial, holding that Defendant was entitled to postconviction relief as to the guilt phase of his trial.A jury found Defendant guilty of two murders, and the trial court ultimately imposed a sentence of death for each murder. The Supreme Court affirmed on direct appeal. Defendant subsequently filed a motion for postconviction relief, raising several Brady claims as to the guilt phase of his trial. The postconviction court denied relief. The Supreme Court reversed the denial of postconviction relief as to the guilt phase and vacated Defendant's murder convictions, holding (1) the State committed a Brady violation by failing to disclose that one of the witnesses was a confidential informant for the State; and (2) the Brady violation undermined confidence in the outcome of the trial. View "Simpson v. State" on Justia Law

The Supreme Court held that when a defendant voluntarily chooses to allocate at a sentencing hearing, the sentencing court is permitted to consider the defendant's freely offered statements, including those indicating the defendant's failure to accept responsibility.On appeal from the judgment of the trial court in this case, the First District concluded that "lack of remorse and refusal to accept responsibility can be valid sentencing considerations when sentencing within the statutory range." The Supreme Court approved the result in the decision on review, holding that the sentencing judge in this case was entitled to consider testimony that indicated Defendant's unwillingness to accept the truth and to take responsibility for his conduct. View "Davis v. State" on Justia Law

The Supreme Court sanctioned Petitioner after dismissing his petition for a writ of habeas corpus, holding that Petitioner failed to show cause why he should not be barred from filing any further pro se requests for relief.Since 2018, Petitioner, who was convicted of false imprisonment and aggravated battery, had filed sixteen petitions with the Supreme Court, including the petition at issue in this case, all without success. The Supreme Court dismissed the instant petition as a repetitive claim and held that, based on Petitioner's history of filing pro se petitions and requests for relief that were meritless or otherwise inappropriate for review, the clerk of court should reject any future pleadings or requests for relief submitted by Petitioner pertaining to his criminal case. View "Martin v. Dixon" on Justia Law

The Supreme Court approved the holding of the Second District Court of Appeal in this case, which involved an appeal of a conviction for driving as a habitual traffic offender (HTO) while one's driver's license is revoked (DWLR-HTO), holding that the court below reached the correct result.The district court held that, under Fla. Stat. 322.34(5), a conviction for DWLR-HTO does not require the State to prove that the Florida Department of Highway Safety and Motor Vehicles (DHSMV) provided Defendant with notice of the HTO driver license revocation. The Supreme Court approved the district court's ruling, holding that proof that DHSMV provided a defendant with notice of an HTO driver license revocation is not an element of the crime of DWLR-HTO under section 322.34(5). View "Robinson v. State" on Justia Law

The Supreme Court approved the decision of the First District Court of Appeal in this case, holding that Fla. Stat. 942.051(3), which prohibits raising an unpreserved claim of error on direct appeal absent a showing of fundamental error, precludes appellate review of unpreserved claims of ineffective assistance of trial counsel on direct appeal.Defendant was found guilty of first-degree murder. On appeal, Defendant argued that he received ineffective assistance of counsel. The First District affirmed Defendant's convictions and sentence and declined to address his claims of ineffective assistance because he did not preserve any of the errors he advanced on appeal and did not make a claim of fundamental error. The Supreme Court approved of the decision below, holding that the plain text of section 924.051 prohibits raising unpreserved error on direct appeal absent a showing of fundamental error. View "Steiger v. State" on Justia Law