Justia Florida Supreme Court Opinion Summaries

Appellant appealed an order of the circuit court denying his motion to vacate his convictions of first-degree murder and sentences of death filed under Florida Rule of Criminal Procedure 3.850 and petitioned the court for a writ of habeas corpus. At issue was whether appellant's trial counsel rendered ineffective assistance of counsel during the penalty phase because he failed to investigate, develop, and present available mitigating evidence that would have legally precluded an override of the jury's life recommendation. The court held that it was clear that trial counsel's failure to investigate, develop and present available mitigation evidence not only undermined confidence in the outcome of the trial proceedings, but also precluded the court from making a proper disposition of the case on direct appeal. The court also held that a new sentencing proceeding before a trial court was unnecessary in postconviction jury override cases, just as it was unnecessary to direct appeal jury override cases. Accordingly, the court affirmed the postconviction court's denial of rule 3.850 relief with respect to the first-degree murder convictions but reversed the court's denial of relief with respect to the death sentences. The court vacated appellant's death sentence and remanded for imposition of a life sentence on each of the first-degree murder counts and the trial court had discretion to impose the sentences concurrently or consecutively. View "Coleman v. State; Coleman v. Buss, et al. " on Justia Law

Defendant was adjudicated guilty of the sale and possession of cocaine, a second degree felony, and sentenced as a habitual felony offender ("HFO") to thirty years in prison and received a split sentence where he was to serve the first 20 years of his sentence in prison and the remaining portion as a suspended sentence to be satisfied by probation. After 12 years, defendant was released from prison and subsequently committed technical violations of his probation twice by testing positive for cocaine. At issue in a certified question was whether defendant lost his status as an HFO if the trial court did not repeat this status at the sentencing hearing on violation of probation ("VOP") where defendant had been declared to be an HFO before the imposition of his initial split sentence and when he later violated probation and had his probation revoked. The court held that the absence of any clear intent of designating defendant as an HFO and the trial court's subsequent imposition of an HFO status to his VOP judgment and sentence after he began serving his sentence violated double jeopardy and amounted to an illegal sentence and manifest injustice. Because defendant's sentence was illegal, the district court was proper in correcting it and therefore, the court affirmed the district court's decision and answered the certified question in the affirmative.

Petitioner received a 30 year sentence for burglary, a 10 year sentence for auto theft, and a life sentence for kidnapping where petitioner's sentences stemmed from his theft of a vehicle in which a two-year-old child was asleep in the backseat. At issue was whether petitioner committed the additional crime of kidnapping if he did not know the child was in the backseat before or during his commission of the auto theft, which was the underlying felony used to support his kidnapping conviction. The court held that, because the State failed to produce sufficient evidence demonstrating petitioner's awareness of the victim before or during his execution of the underlying felony, critical statutory requirements for the kidnapping offense were not satisfied. Therefore, the district court's decision relying on the Faison v. State three-part test to affirm the trial court's denial of petitioner's motion for judgment of acquittal was erroneous.

Petitioner requested a judgment of acquittal on the charge of felony criminal mischief where defense counsel argued that the state failed to establish a prima facie case that the damage to the doors that petitioner drove into was one thousand dollars or more, the threshold amount for the felony charge. At issue was whether the Third District Court of Appeal properly relied on a "life experience" exception to the general rule that a state must establish the amount of damage to prove felony criminal mischief. The court quashed the Third District's decision, disapproved of Jackson v. State, and other decisions in this context that applied to the "life experience" exception and held that before a defendant could be convicted of felony criminal mischief, the state must prove the amount of damage associated with the criminal conduct.

Petitioner appealed the trial court's order denying his motion filed under Florida Rule of Criminal Procedure 3.851 to vacate his conviction of first degree murder and sentence of death. Petitioner raised numerous claims of trial court error, ineffective assistance of counsel, and habeas relief. The court held that the trial court properly determined that counsel was not ineffective for offering the testimony of petitioner's brother; petitioner failed to demonstrate that counsel was ineffective in presenting the mental health mitigation; the trial court properly denied petitioner's claim that counsel was ineffective in allowing the admission of petitioner's confession to a prior murder; the trial properly admitted evidence of petitioner's prior murder conviction; counsel was not ineffective for failing to move to suppress petitioner's statements of law enforcement; petitioner was not entitled to relief where counsel was ineffective for failing to inform the jury that petitioner was medicated during a prior, unrelated trial; counsel was not ineffective for failing to object to erroneous jury instructions; and the trial court did not err in summarily denying several of petitioner's claims. The court also held that petitioner was not entitled to habeas relief where all of his claims were either without merit or procedurally barred.

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.