Justia Florida Supreme Court Opinion Summaries

The Supreme Court quashed the decision of the Fourth District Court of Appeal in this juvenile sentencing case remanding for the trial judge to remedy a harmful Alleyne error through a "ministerial correction" of sentence for which the defendant "need not be present," holding that the remedy fell short of the de novo sentencing required by Williams v. State, 242 So. 3d 280 (Fla. 2018).At issue was the proper remedy for a harmful Alleyne error that occurs where, in sentencing a juvenile offender under Fla. Stat. 775.082(1)(b), the trial court enhances the sentence without a jury finding of the fact that authorizes the enhancement. In this case, Defendant, who committed two homicides, argued that he should be resentenced because the jury was not asked to find, and did not find, that he "actually killed, attempted to kill, or intended to kill the victims," as required under section 775.082(1)(b)1. The Fourth District concluded that the trial court committed a harmful Alleyne error in resentencing Defendant and remanded for "ministerial correction" of Defendant's sentences, for which Defendant "need not be present[.]" The Supreme Court quashed the Fourth District's decision, holding that Defendant was entitled to the de novo resentencing required by Williams. View "Puzio v. State" on Justia Law

The Supreme Court affirmed the sentence of death that was imposed at Defendant's resentencing for the first-degree murder of Seath Jackson, holding that Defendant's claims of error were unavailing.The Supreme Court previously affirmed Defendant's conviction for first-degree murder with a firearm but vacated his sentence of death and remanded for a new penalty phase based on Hurst v. State, 202 So. 3d 40 (Fla. 2016). After a new penalty phase, the judge again imposed a sentence of death. The Supreme Court affirmed, holding (1) the State was not precluded from seeking the death penalty; (2) Defendant's argument that the court erred in allowing evidence of post-death acts was not adequately preserved for review; (3) the circuit court did not abuse its discretion in assigning little or no weight to mental mitigation factors; (4) the circuit court properly considered Defendant's age and certain other mitigating circumstances; and (5) the death sentence was not disproportionate. View "Bargo v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's motion for a determination of intellectual disability as a bar to execution and his amended successive motion for postconviction relief, holding that relief was properly denied.Appellant was convicted of murder and sentenced to death. Appellant later filed a successive motion for postconviction relief seeking to vacate his death sentence on the ground that he was intellectually disabled. Appellant also brought claims under Hurst v. Florida, 577 U.S. 92 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The trial court ultimately denied Appellant's intellectual disability and Hurst-related claims. The Supreme Court affirmed, holding that the trial court did not err in denying relief. View "Haliburton v. State" on Justia Law

The Supreme Court denied Petitioner's petition for review of the decision of the First District Court of appeal concluding that it was not error for a successor judge to deny Petitioner's Fla. R. Crim. P. 3.800(b) motion, holding that this Court lacked jurisdiction.In seeking review, Petitioner argued that the Supreme Court had jurisdiction because of the lower court's decision's "apparent conflict" with the decision of the Second District Court of Appeal in Gay v. State, 898 So. 2d 1203 (Fla. 2d DCA 2005) and because the decision affected judges. The Supreme Court denied review, holding that the district court decisions alleged to be in conflict were materially distinguishable, and therefore, the Supreme Court had no discretion to review due to lack of jurisdiction. View "Kartsonis v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree murder and his sentence of death, holding that Defendant's claims on appeal failed.Specifically, the Supreme Court held (1) the trial court's failure to renew an offer of counsel before commencing the penalty phase did not constitute fundamental error because the trial court cured the error; (2) no error occurred as a result of the prosecutor's statement that he would ask the jury to return a recommendation of death; (3) a challenged guilt-phase instruction was in error, but the error was not fundamental; (4) Defendant waived his claim that a Fifth Amendment violation occurred; (5) the trial court did not err in instructing the penalty-phase jury; and (6) the evidence was sufficient to support the conviction. View "Allen v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court summarily denying Appellant's third successive motion for postconviction relief, filed under Fla. R. Crim. P. 3.851, holding that the postconviction court properly denied relief.Appellant was convicted of first-degree murder, burglary with assault or battery, and retaliation against a witness. The trial judge sentenced Appellant to death after a second penalty phase. The Supreme Court affirmed the convictions and sentences. In his third successive postconviction motion, Appellant alleged newly discovered evidence of both Brady violations and violations under Giglio v. United States, 405 U.S. 150 (1972). The circuit court summarily denied relief. The Supreme Court affirmed, holding that, even if Appellant's claims were not procedurally barred, Appellant failed to demonstrate that the alleged newly discovered evidence would likely produce an acquittal on retrial. View "Bogle v. State" on Justia Law

The Supreme Court held that a defendant who does not comply with the Florida rule of appellate procedure requiring a criminal defendant to file a motion to withdraw the plea in the trial court before appealing an involuntary plea must seek any available relief through collateral review.Defendant pleaded no contest to certain charges. After Defendant was sentenced his counsel filed a notice of appeal. Despite the preservation requirement of Fla. R. App. P. 9.140(b)(2)(A)(ii)(c), Defendant did not first file a motion to withdraw his plea. On appeal, the Fourth District concluded that the trial court had committed fundamental error by failing to holding a hearing on Defendant's competency and that, under the circumstances, it was not necessary for Defendant first to file a motion to withdraw plea. The Supreme Court quashed the decision below, holding that there is no fundamental-error exception to the preservation requirement of Rule 9.140(b)(2)(A)(ii)(c). View "State v. Dortch" on Justia Law

The Supreme Court affirmed the order of the circuit court granting Defendant's motion to dismiss postconviction counsel and proceedings, filed pursuant to Fla. R. Crim. P. 3.851, holding that the circuit court properly accepted Defendant's waiver.Defendant was sentenced to death of the murders of his infant son and the child's mother. Eight years later, Capital Collateral Regional Counsel (CCRC) was appointed to represent Defendant in postconviction proceedings. Defendant filed a pro se motion to monitor and remove CCRC counsel and to waive postconviction counsel and proceedings. The court found that Defendant's waiver of postconviction counsel and proceedings was knowing, intelligent, and voluntary and orally accepted Defendant's waiver. The Supreme Court affirmed, holding that the postconviction court did not err in concluding that Defendant was competent to waive postconviction counsel and proceedings. View "Wall v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court summarily denying Appellant's second successive motion to vacate his judgment of conviction of first-degree murder and sentence of death, holding that the postconviction court did not err.On appeal, Appellant argued that the postconviction court's failure to hold a case management hearing pursuant to Huff v. State, 622 So. 2d 982 (Fla. 1993), was erroneous and that the court erred in denying relief without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) Appellant's claim of juror misconduct was not procedurally barred; and (2) summary denial was proper because Appellant's allegations of juror dishonesty and actual bias were legally insufficient to state a claim. View "Boyd v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's second and third amended motions to vacate judgment and sentence, holding that the circuit court did not err.Defendant was convicted of one count of first-degree murder and one count of armed robbery. Defendant was sentenced to death for the murder. During voir dire, one potential juror, juror Smith, remained silent when asked about prior arrests when, in actuality, the juror had been adjudicated delinquent for sexual battery as a minor. In his postconviction motions, Defendant alleged that juror Smith's misconduct provided a basis for postconviction relief. The trial court denied relief. The Supreme Court affirmed, holding that Defendant's factual allegations, taken as true, would not demonstrate error on the part of trial counsel. View "Martin v. State" on Justia Law