Justia Florida Supreme Court Opinion Summaries

Respondent filed a petition for writ of habeas corpus alleging that he was entitled to immediate release where respondent's claim concerned the sentences that were imposed following his violation of probation. At issue was whether a court may sua sponte dismiss a petition for a writ of habeas corpus, in which a prisoner was seeking immediate release, based upon the petitioner's failure to allege exhaustion of administrative remedies. The court held that, in light of the constitutional and statutory authorities and precedent, the habeas petition could not be dismissed based upon the petitioner's failure to exhaust administrative remedies where such failure had not been raised by the parties.

Respondent appealed his sentence when he was convicted of aggravated battery with great bodily harm, permanent disability, or permanent disfigurement; shooting within a dwelling; and false imprisonment. At issue was whether, in cases in which convictions were final before Apprendi v. New Jersey was issued, Apprendi and Blakely v. Washington applied to resentencing proceedings held after Apprendi issued where the sentencing was not final when Blakely issued. The court held that Apprendi and Blakely applied to such resentencings conducted after Apprendi and Blakely issued where resentencing was a de novo proceeding in which the decisional law effective at the time of the resentencing applied.

The State charged Petitioner Clayton Harris with possession of pseudoephedrine with the intent to manufacture methamphetamine, in violation of state law. On a traffic stop, officers noticed that Petitioner was "shaking, breathing rapidly, and could not sit still." When Petitioner did not consent to a search of his vehicle, officers brought over their drug-sniffing dog to conduct a "free sniff" of the exterior of the vehicle. The dog alerted to the smell of drugs on the driver's side door. Using the alert as the basis of a warrantless search of the interior, officers discovered pseudoephedrine under the driver's seat and 8 boxes of matches. Petitioner was placed under arrest, and after being read his Miranda rights, stated that he had been cooking meth at least two weeks prior to this traffic stop. At trial, the State argued that the arresting officer had probable cause based on his observations from the stop: an expired plate-tag, Petitioner's nervousness, and an alert from a trained drug-sniffing dog. Petitioner challenged the dog's reliability. The trial court denied the motion to suppress, found that there was probable cause to search Petitioner's vehicle, and admitted all physical evidence seized. The Supreme Court granted discretionary review to resolve a conflict between the district courts on whether a drug-sniffing dog's alert to its handler can provide probable cause to conduct a warrantless search of the interior of a vehicle. The Court held that the dog's alert alone is not enough; the State must present evidence of the dog's training and certification records; the trial court must assess the reliability of the dog's detection. In this case, the Court reviewed the totality of the circumstances to find that the trial court should have granted Petitioner's motion to suppress; the Court remanded this case for further proceedings.

After being charged with possession of cocaine with intent to sell within 1000 feet of a school, Respondent Anthony Hankerson filed a motion to suppress evidence, asserting that the evidence against him was obtained from an illegal search and seizure. Specifically, Respondent asserted that the officer that searched him lacked probable cause to believe he committed a felony. At the hearing on the motion to suppress, the State contended that the search was properly based on probable cause and presented testimony from two law enforcement officers. The trial court denied Respondent's motion to suppress and the State appealed; the appellate court concluded the trial court erred in finding the officers had probable cause to search Respondent. On review of the cases below, the Supreme Court found the record contained ample evidence to support the trial court's decision to deny Respondent's motion to suppress, and quashed the appellate court's decision.

Petitioner Andrea Johnson plead guilty to armed robbery and possession of a firearm, and was placed on probation for four years conditioned on his participation in a "boot camp" program. Johnson violated the terms of the probation. The State and Johnson reached an agreement on sentencing which specified that Johnson would receive a sentence of four years of incarceration, and credit for time served. The court clerk executed a document reflecting the agreement, but Johnson asserted the agreement should have received credit for the time spent in boot camp, which was outside the time covered by the agreement. The trial court denied Johnson's pro se motion seeking credit for time spent in boot camp. On appeal, the court upheld the lower court's decision, holding that Johnson validly waived any additional credit in consenting to the terms of the plea agreement. Petitioner Bernard Joyner's case was procedurally similar to Johnson's: Joyner plead guilty to false imprisonment, and was sentenced to five years probation. Violating the terms of his probation, Joyner and the State reached a plea agreement where Joyner would be sentenced to two years on incarceration. The court clerk executed an agreement for time served. Joyner asserted that he should have received additional credit for time served, but the trial court denied his motion. The appellate court denied both petitioners relief; the Supreme Court consolidated the cases and affirmed the appellate court's decision, finding that Petitioners' challenged are not cognizable under state law.

Appellant-Cross Appellee Seibert was denied a post-conviction motion to vacate his first-degree murder conviction and death sentence. On appeal, Appellant sought review of whether the post-conviction court erred in denying his claim of ineffective assistance of counsel during the guilt and sentencing phases of trial, and whether that court erred in denying him access to public records. In raising this appeal, Appellant sought a writ of habeas corpus. The State cross-appealed the post-conviction court's order to produce certain records on lethal injection protocols. After review of lower court records and trial transcripts, the Court found that Appellant was not entitled to relief and affirmed the post-conviction court''s disposition of the case, an denied Appellant the writ of habeas corpus. The Court upheld the lower court's ruling on the State's public records cross-appeal.

The Court considered whether a "sniff test" by a drug detection dog conducted at the front door of a private residence is 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 is probable cause or reasonable suspicion. A Crimestoppers tip alerted police to a private home where drugs were suspected; officers arrived at the house with a drug detection dog. The dog alerted to the scent of marijuana, and on approaching the house, police then smelled the scent. The magistrate supressed the evidence seized at the home, and the State appealed. Petitioner Jardines sought review by the Court on a certified question that conflicted with state law pertaining to whether the "sniff test" was a violation of his constitutional rights. Concluding that the dog "sniff test" conducted here was an intrusive procedure because it took place in the home, the Court held that results of the "sniff test" were properly withheld from the magistrate's probable cause determination.