Justia Florida Supreme Court Opinion Summaries

Defendant appealed the denial of his amended and supplemental motions for postconviction relief and petitioned for writ of habeas corpus where he was convicted of first degree murders and sentenced to death for the commission of a triple homicide. Defendant raised numerous claims before the court on appeal but focused primarily on two of those claims: whether the state presented expert testimony on comparative bullet lead analysis (CBLA), which evidence had now established was no longer a reliable science, and whether newly discovered evidence showed that a critical state witness testified untruthfully. The court held that the 2008 letter at issue clearly qualified as newly discovered evidence; thus, the postconviction court erred in finding that the claim was procedurally barred and that the letter did not constitute newly discovered evidence. Regardless of these errors, the court affirmed the postconviction court's denial of relief because defendant could not demonstrate that consideration of the letter would probably produce an acquittal on retrial under the newly discovered evidence standard. The court also held that, as to the Brady v. Maryland and Giglio v. United States claims, there was no basis for concluding that the state withheld favorable evidence under Brady or knowingly presented evidence at the original trial under Giglio. After the FBI discovered the errors in the original CBLA evidence introduced at trial, defendant was made aware of these errors by letter. The court rejected defendant's ineffectiveness claim because the record showed that trial counsel retained an independent expert to evaluate the FBI's CBLA and the expert provided counsel with no basis to challenge that analysis. Therefore, the court affirmed the postconviction court's denial of relief and also denied defendant's habeas petition. View "Wyatt v. State; Wyatt v. Buss" on Justia Law

Defendant appealed from a judgment of conviction of first degree murder and a sentence of death. Defendant was also convicted of home invasion robbery with a firearm, kidnapping, and aggravated fleeing and eluding a law enforcement officer. Defendant raised various issues on appeal regarding his post-arrest interrogation; letter of apology; victim impact statements; how the murder was committed in a cold, calculated, and premeditated manner; how the murder was especially heinous, atrocious, or cruel; proportionality of the sentence; Ring v. Arizona; and sufficiency of the evidence. The court addressed each of defendant's claims and held that the convictions and sentences were affirmed. View "Baker v. State" on Justia Law

Defendant was convicted of four counts of first-degree murder and was sentenced to death for each of the murders. On direct appeal, defendant raised eleven claims regarding his competency at trial, his self-representation, limitations on his narrative testimony, the prosecutor's closing argument, evidence of collateral acts, removals from the courtroom, penalty phase jury instructions, his limitation on mitigating evidence, sufficiency of the evidence, and proportionality review of the sentence. The court addressed each claim and concluded that defendant's convictions and sentences of death were affirmed. View "McCray, II v. State" on Justia Law

Defendant was arrested and charged with possession of cannabis in an amount greater than 25 pounds, but less than 2000 pounds. Defendant filed a motion to suppress all evidence seized based on the May 16, 2007 warrant. At issue was whether a law enforcement officer's failure to sign an affidavit in support of a search warrant invalidated the warrant. The court held that the failure of the law enforcement officer to sign the affidavit did not render the search warrant invalid because, based upon all the circumstances surrounding the issuance of the warrant, the error constituted a technical flaw. Accordingly, the trial court erred by suppressing the evidence exclusively on that basis. View "Moreno-Gonzalez v. State" on Justia Law

Petitioner, a juvenile, was convicted for trespassing upon the grounds of a school facility in violation of section 810.097(2), Florida Statutes. At issue was whether the prosecution must prove the identity of the individual who warned defendant to leave the grounds of the school, and that individual's authority to restrict access to the property, as essential elements of the trespass offense. The court held that the individual's identity and authority were essential elements of the offense and quashed the decision of the Third District. The court also held that, because in this case the state failed to present any evidence demonstrating that the petitioner was warned to leave by the school's principal or a designee of the principal, petitioner's conviction must be vacated. View "D.J. v. State" on Justia Law

This case stemmed from a warrantless "sniff test" by a drug detection dog at defendant's home and the subsequent discovery of live marijuana plants inside. At issue was whether the "sniff test" was a search under the Fourth Amendment and if so, whether the evidentiary showing of wrongdoing that the government must make prior to conducting such a search was probable cause or reasonable suspicion. The court held that in the present case, the "sniff test" was a substantial government intrusion into the sanctity of the home and constituted a search within the meaning of the Fourth Amendment. The court also held that probable cause, not reasonable suspicion, was the proper evidentiary showing of wrongdoing that the government must make prior to conducting the "sniff test." Accordingly, the court quashed the district court's decision. View "Jardines v. State" on Justia Law

Defendant was convicted of robbery with a deadly weapon and first degree murder. Defendant appealed his conviction and sentence of death under Florida Rule of Criminal Procedure 3.850. The court affirmed and held that the post conviction court did not err when it denied postconviction relief because trial counsel was not ineffective and the life sentence of the co-defendant did not constitute newly discovered evidence. View "Nelson v. State" on Justia Law

Defendant was convicted of first degree murder, armed burglary, attempted sexual battery, and armed robbery, and sentenced to death. Defendant appealed the circuit court's denial of his motion to vacate his conviction and sentence under Florida Rule of Criminal Procedure 3.851, raising eleven claims. Defendant also filed a petition for writ of habeas corpus, raising nine claims. The court discussed and disposed of each claim and subsequently affirmed the circuit court's judgment and denied defendant's habeas petition. View "Barwick v. State; Barwick v. Buss, etc." on Justia Law

Defendant was convicted of first-degree murder of his step-daughter and sentenced to death. At issue was whether the trial court erred in admitting collateral crime evidence; whether the trial court erred in finding the cold, calculated, and premeditated (CCP) aggravator; and whether the death sentence was proportionate. The court held that the collateral crime evidence that defendant was engaged in an illegal sexual relationship with his stepdaughter's minor daughter was relevant to establish motive and inextricably intertwined with the testimony of the chain of events. The court also held that the CCP aggravator was supported by competent, substantial evidence. The court held, however, that the death penalty was disproportionate in light of the circumstances and in light of three statutory mitigating factors: (1) the defendant was under the influence of extreme mental or emotional disturbance at the time the capital felony was committed; (2) the capacity of defendant to appreciate the criminality of his conduct or conform his conduct to the requirements of law was substantially impaired; and (3) the age of the defendant. Accordingly, the court confirmed the conviction but vacated the sentence of death and reduced defendant's sentence to life imprisonment without the possibility of parole.View "Ballard v. State" on Justia Law

The State sought review of the district court's reversal of defendant's convictions for possession of cocaine for sale. At issue was whether the district court erred in refusing to consider the State's argument on appeal that the evidence was legally discovered following a proper investigatory stop because the theory had not been raised in the trial court. The court held that the Fourth District's refusal to consider the state's theory expressly and directly conflicted with Dade County School Board v. Radio Station WQBA, which held that "an appellee, in arguing for the affirmance of a judgment, is not limited to legal arguments expressly asserted as grounds for the judgment in the court below." Therefore, the court concluded that the Fourth District properly determined that the factual circumstances of the case supported the trial court's conclusion that police officers had probable cause to search defendant. Accordingly, the Fourth District's decision was quashed. View "State v. Hankerson" on Justia Law