Justia Florida Supreme Court Opinion Summaries

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

The Supreme Court affirmed the sentence of death imposed on Defendant after a new penalty phase ordered by the Supreme Court, holding that there was no error in the proceedings below.Defendant was convicted of first-degree murder. The trial court sentenced Defendant to death. The Supreme Court remanded for a new penalty phase pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016), after, after a new penalty phase, the jury returned a unanimous verdict recommending that Defendant be sentenced to death. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding that Defendant failed to show error, much less prejudicial error. View "Deviney v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions of first-degree murder, sexual battery of a person under twelve years old, and kidnapping, and the imposition of the death penalty, holding that there was no prejudicial error in this case.Specifically, the Supreme Court held (1) the trial court did not commit fundamental error in failing to grant Defendant's motion for change of venue; (2) the trial court did not abuse its discretion in denying Defendant's motion for a mistrial on account of the interruption to the testimony of the state's expert; (3) the trial court did not abuse its discretion in denying Defendant's motion to exclude autopsy photographs during certain testimony; (4) Defendant was not entitled to relief on his claim that the state made inappropriate comments in its opening statement and in closing argument; and (5) there was no cumulative error in this case. View "Smith v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and his sentence of death, holding that Defendant failed to demonstrate any reversible error.Defendant pleaded guilty to first-degree murder and was sentenced to death. Defendant appealed, raising ten allegations of error. The Supreme Court affirmed, holding (1) the trial court did not err in allowing Defendant to represent himself during trial; (2) the trial court did not err in accepting Defendant's guilty plea; (3) the trial properly renewed the offer of counsel at all critical stages of the proceedings; (4) there was no reversible error in the trial court's findings on the statutory aggravators alleged by the State and on certain statutory and non statutory mitigators; (5) any error in the trial court's inclusion of a sentencing recommendation in the presentence investigation report did not rise to the level of fundamental error; and (6) Defendant was not entitled to relief on his remaining allegations of error. View "Woodbury v. State" on Justia Law

The Supreme Court affirmed the judgment of the postconviction court denying Appellant's initial postconviction motion filed under Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief on his allegations of error.Appellant was convicted of two counts of first-degree premeditated murder and one count of escape while being transported. The trial court sentenced Appellant to death. Appellant later filed a postconviction motion raising seven claims. The circuit court granted an evidentiary hearing on most of Appellant's claims and then denied the postconviction motion as to all claims. The Supreme Court affirmed, holding that the postconviction court did not err in denying Appellant's claims of newly discovered evidence, ineffective assistance of counsel, cumulative error, and a Brady violation. View "Morris v. State" on Justia Law

The Supreme Court approved the decision of the First District Court of Appeal dismissing Defendant's appeal of the denial of his motion filed under Fla. R. Crim. P. 3.800(a), holding that Defendant could not show that the denial of his rule 3.800(a) motion was in error.Defendant was convicted of armed robbery of a firearm and kidnapping to facilitate a felony and sentenced to concurrent life sentences for both counts. In his rule 3.800(a) motion, Defendant argued that his life sentences were illegal because the trial court failed to impose ten-year mandatory minimum sentences pursuant to Fla. Stat. 775.087(2). The postconviction court denied the motion, concluding that the sentencing judge's failure to impose the ten-year mandatory minimum sentences did not render Defendant's sentences illegal because he did not benefit from the error. The court of appeals affirmed. The Supreme Court affirmed, holding that Defendant could not show that the denial of his rule 3.800(a) motion resulted in harm that may be remedied on appeal. View "Earl v. State" on Justia Law

The Supreme Court answered in the affirmative a question certified to it by the Fifth District Court of Appeals and quashed the Fifth District's decision in this case, holding that the lowest permissible sentence as defined by Fla. Stat. 921.0024(2) is an individual minimum sentence and not a collective minimum sentence where there are multiple convictions subject to sentencing on a single scoresheet.Defendant was convicted of attempted first-degree murder and other crimes. The Fifth District reversed the attempted first-degree murder, and Defendant was resentenced for his remaining conviction. The Criminal Punishment Code Scoresheet indicated that the lowest permissible sentence (LPS) was 107.25 months. The trial court concluded that the LPS is an individual minimum sentence that must be applied to each offense if the LPS exceeds each individual statutory maximum sentence. The Fifth District reversed, ruling that the LPS is an individual minimum sentence that applies to each offense even though the LPS did not exceed the statutory maximum sentence for the primary offense. The Supreme Court quashed the Fifth District's decision, holding that the LPS is an individual minimum sentence that must be imposed when the LPS exceeds the statutory maximum sentence for each offense. View "State v. Gabriel" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Appellant's successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the postconviction court did not err.Appellant filed a successive postconviction motion claiming that, based on the prosecutor's peremptory strike of a juror for allegedly racial reasons, he was entitled to relief under Flowers v. Mississippi, 139 S. Ct. 2228 (2019). The postconviction court denied the motion, finding it to be procedurally barred, untimely, and without merit. The Supreme Court affirmed, holding that the successive motion was procedurally barred and untimely. View "Willacy v. State" on Justia Law