Justia Florida Supreme Court Opinion Summaries

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

The Supreme Court approved the holding of the First District Court of Appeal concluding that a defendant convicted by a jury verdict after raising a self-defense claim is not entitled to a new immunity hearing if the trial court applied the incorrect standard at the hearing under Fla. Stat. 776.032, holding that the First District did not err.Under 776.032, Florida's Stand Your Ground law, a person is generally immune from criminal prosecution and civil action when that person justifiably uses or threatens to use force under certain circumstances. At issue in this case was the proper remedy for the application of an incorrect burden of proof at an immunity hearing. The First District affirmed Defendant's conviction and sentence but certified conflict with Nelson v. State, 295 So. 3d 307 (Fla. 2d DCA 2020), in which the Second District held that a defendant is entitled to a new immunity hearing after the trial court erroneously applied the burden of proof in his immunity hearing, even though he had subsequently been convicted by a jury. The Supreme Court affirmed and disapproved the decision of the Second District in Nelson. View "Boston v. State" on Justia Law

The Supreme Court quashed the decision of the Fifth District Court of Appeal concluding that the circuit court lacked jurisdiction to impose a sexual predator designation on an offender who qualified under the Florida Sexual Predators Act, Fla. Stat. 775.21, when the sentencing court did not impose the designation at sentencing and the offender's sentence had been completed, holding that the Fifth District erred.In 2009, Defendant was sentenced to six months' incarceration, followed by two years of sex offender community control, followed by three years of sex offender probation. In 2015, Defendant completed all portions of his sentence. In 2018, the State filed a notice stating that Defendant's original offense was an enumerated offense under section 775.21, thus obligating the trial court to designate Defendant as a sexual predator. The trial court determined that Defendant must comply with the registration requirements because section 775.21 placed an obligation on the court to designate Defendant as a sexual predator. The Fifth District reversed. The Supreme Court reversed, holding that section 775.21 confers jurisdiction on a trial court to designate a sexual predator after he is sentenced and completes his probation. View "State v. McKenzie" on Justia Law

The Supreme Court affirmed Defendant's judgments of conviction of first-degree murder and sentences of death, holding that there was no prejudicial error in the proceedings below.Defendant was convicted and sentenced to death for his role in a 2016 triple homicide. The Supreme Court affirmed the convictions and sentences, holding (1) certain prosecutorial comments challenged by Defendant did not constitute fundamental error; (2) the trial court did not err in permitting the use of a map as a demonstrative aid; (3) there was no error in the State's presentation of victim impact evidence; and (4) the evidence was sufficient to support the convictions. View "Alcegaire v. State" on Justia Law

The Supreme Court approved the decision of the First District Court of Appeal affirming Defendant's conviction of of three counts of sexual battery and one count of lewd or lascivious exhibition, holding that the schedule of lesser included offenses promulgated by the Florida Supreme Court in 2018 incorrectly classified sexual battery as a necessarily lesser included offense of capital sexual battery.On appeal, Defendant argued that the trial court erred in denying his motion to instruct the jury on sexual battery as a category one, necessarily lesser included offense of capital sexual battery. The First District affirmed. The Supreme Court affirmed, holding that sexual battery is not a necessarily lesser included offense of capital sexual battery. View "Allen v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying Defendant's claims that he was intellectually disabled and therefore ineligible for the death penalty and that he was entitled to relief under Hurst v. Florida, 577 U.S. 92 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016), holding that there was no error.Defendant was convicted and sentenced in death in 1985 for first-degree murder. Before the Supreme Court in this case was Defendant's successive motion under Fla. R. Crim. P. 3.203 raising an intellectual disability claim. The trial court denied the claim, concluding that Defendant had not established intellectual disability and that Defendant was not entitled to relief under Hurst. The Supreme Court affirmed, holding that Defendant failed to establish that he was entitled to relief. View "Nixon v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeal that invited error precluded review of Defendant's claim on appeal that a jury charge was coercive, holding that the court of appeal did not err.Defendant was convicted of manslaughter with a deadly weapon, two counts of attempted manslaughter, and unlawful possession of a firearm by a minor. Defendant appealed, arguing that the jury's verdict was coerced by the trial court's issuance of a second modified Allen charge, which defense counsel requested. The court of appeal affirmed, concluding that although the charge was coercive, Defendant waived the error by agreeing to the modified charge. The Supreme Court affirmed, holding that the invited error precluded review for fundamental error. View "Baptiste v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Gary Hilton's motion to vacate his conviction of first-degree murder and sentence of death and denied Hilton's petition for a writ of habeas corpus, holding that Hilton was not entitled to relief.Specifically, the Supreme Court held (1) as to Hilton's claims of ineffective assistance of counsel, Defendant's allegations of deficient performance were insufficient to satisfy Strickland, and the postconviction court did not err in denying Hilton's claim that he was entitled to relief under Hurst v. Florida, 577 U.S. 92 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016); and (2) as to Hilton's petition for writ of habeas corpus, some claims were procedurally barred and, as to his remaining claims, Hilton was not entitled to relief. View "Hilton v. State" on Justia Law