Justia Florida Supreme Court Opinion Summaries

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

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death, holding that Defendant's arguments on appeal were unavailing.Specifically, the Supreme Court held that the trial court did not abuse its discretion in granting Defendant's request for self-representation because (1) a competency hearing was not required; (2) substantial evidence supported the findings that Defendant's waiver of the right to counsel was knowing, voluntary, and intelligent under Faretta v. California, 422 U.S. 806; and (3) the trial court was not required to find that Defendant suffered from severe mental illness to the point that he was incompetent to conduct trial proceedings by himself. View "Noetzel v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's third successive motion for postconviction relief, filed under Fla. R. Crim. P. 3.851, holding that there was no error.Appellant was convicted of first-degree murder, armed robbery, and grand theft of a motor vehicle. The trial court sentenced Defendant to death. After the Supreme Court affirmed Appellant sought postconviction relief in both state and federal court, without success. At issue was Appellant's third successive postconviction motion in which he raised a single claim of newly discovered evidence based on alleged childhood sexual abuse. The circuit court summarily denied the motion. The Supreme Court affirmed, holding that the circuit court did not err in denying Appellant's postconviction motion without first holding an evidentiary hearing. View "Rogers v. State" on Justia Law

The Supreme Court affirmed the judgment of the postconviction court denying Defendant's petition for postconviction relief as to the guilt phase of his trial and denied his petition for a writ of habeas corpus, holding that Defendant was not entitled to relief.Defendant was convicted of three counts of first-degree murder and sentenced to death for two of the murders. The Supreme Court affirmed. Defendant later filed a motion for postconviction relief, raising sixteen claims. The trial court granted in limited part Defendant's motion for postconviction relief as to a new penalty phase under Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court affirmed, holding (1) the postconviction court did not err in denying Defendant's motion for postconviction relief as to the guilt phase; and (2) Defendant failed to establish that he was entitled to a writ of habeas corpus. View "Smith v. State" on Justia Law