Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction for first-degree murder and his sentence of death, holding that no error occurred in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion in denying Defendant's request for self-representation as equivocal; (2) the trial court did not abuse its discretion in denying Defendant's peremptory challenge to an African American juror; (3) the trial court did not err in instructing the penalty phase jury; (4) the trial court did not abuse its discretion by admitting statements made by Defendant's prior victim in support of the prior violent felony aggravator; (5) competent, substantial evidence supported the trial court's finding of the HAC aggravator and the CCP aggravator; (6) Craven’s death sentence was proportionate; and (7) the evidence was sufficient to support Defendant's conviction for first-degree murder. View "Craven v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Defendant's successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the circuit court properly denied relief.Defendant was found guilty of first-degree murder and was sentenced to death. In his successive postconviction motion, Defendant claimed that he was entitled to relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016), and that the indictment was defective because it failed to include aggravating factors. The circuit court denied relief. The Supreme Court affirmed, holding (1) this Court's decision in State v. Poole, 297 So. 3d 487 (Fla. 2020), foreclosed relief on Defendant's Hurst claims; and (2) Defendant's claim that the indictment was defective was procedurally barred. View "Lott v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Petitioner's third successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in dismissing the motion as untimely.Petitioner was convicted of first-degree murder, armed robbery, and armed burglary. Petitioner was sentenced to death. The Supreme Court affirmed the convictions and sentence. Petitioner later filed a third successive motion for postconviction relief, raising a claim of newly discovered evidence. The trial court dismissed the motion as untimely. The Supreme Court affirmed, holding that because Petitioner and his counsel failed to exercise diligence in pursuing the facts on which the claim was predicated, the trial court did not err in dismissing the motion. View "Dillbeck v. State" on Justia Law

The Supreme Court concluded that Petitioner's quo warranto petition filed in this case was a frivolous proceeding brought before the Supreme Court by a state prisoner and instructed the Clerk of Court to reject any future filings submitted by Petitioner that are related to two criminal cases unless such filings are signed by a member in good standing of The Florida Bar.Petitioner was convicted in two separate cases of drug-related offenses. Petitioner since filed thirty-four petitions or notices, the majority of which were related to his convictions and sentences in the aforementioned criminal cases. All of the filings were denied, dismissed, or transferred. In this quo warranto petition, Petitioner claimed that the State Attorney for the Twentieth Judicial Circuit failed to acknowledge a habeas petition that he had mailed to her office. The Supreme Court dismissed the petition and concluded that sanctions should be imposed because Petitioner has abused the judicial process and burdened the Supreme Court's limited judicial resources. View "James v. Fox" on Justia Law

The Supreme Court affirmed the decision of the circuit court denying Tina Lasonya Brown's motion to vacate her conviction of first-degree murder and sentence of death under Fla. R. Crim. P. 3.851 and denied Brown's petition for a writ of habeas corpus, holding that Brown was not entitled to relief.As to Brown's postconviction appeal, the Supreme Court held (1) the circuit court did not err in denying Brown's allegations of ineffective assistance of counsel in some respects but erred in denying Brown's allegations of ineffective assistance of counsel in other respects; (2) there was no reasonable probability that bur for trial counsel's deficiencies, individually or cumulatively, the outcome would have been different; (3) the circuit court did not err in denying Brown's claim of newly discovered evidence; and (4) the circuit court did not err in summarily denying Brown's claim that she was not entitled to relief from her death sentence under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). As to Brown's habeas petition, the Supreme Court held that appellate counsel was not ineffective on direct appeal. View "Brown v. State" on Justia Law

The Supreme Court affirmed the circuit court's order summarily denying Defendant's successive emotion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the circuit court properly denied Defendant's claims.Defendant was convicted of first-degree felony murder, aggravated child abuse, and sexual battery and sentenced to death for first-degree felony murder. Defendant later filed a successive postconviction motion claiming that the State committed Giglio and Brady violations. The circuit court summarily denied the motion. The Supreme Court affirmed, holding that the circuit court did not err in summarily denying Defendant's Giglio claim and properly denied Defendant's Brady claim. View "Davis v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Defendant's fifth successive postconviction motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Defendant was not entitled to postconviction relief.Defendant was convicted of first-degree murder and robbery and sentenced to death. In his fifth successive postconviction motion, Defendant argued that his counsel conceded guilt without his consent and that the error was structural. The trial court dismissed the motion on the grounds that it was untimely and that, even if it had been timely, it was without merit. The Supreme Court affirmed, holding that Defendant did not state a facially sufficient claim. View "Atwater v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Defendant's second successive motion for post conviction relief, holding that Defendant was not entitled to postconviction relief.Defendant was convicted of first-degree felony murder and burglary with an assault. The trial judge imposed the death sentence, and the Supreme Court affirmed. Defendant later filed a second successive motion for postconviction relief under Fla. R. Crim. P. 3.851 claiming that he was entitled to relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016), and Atkins v. Virginia, 536 U.S. 304 (2002). The trial court summarily denied the motion. The Supreme Court affirmed, holding (1) Defendant was not entitled to retroactive Hurst relief; and (2) Defendant's intellectual disability claim was untimely. View "Freeman v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily dismissing as untimely Petitioner's successive motion for postconviction relief, holding that the record conclusively established that Petitioner was not entitled to relief.In 1993, Petitioner was convicted of first-degree murder and sentenced to death. The Supreme Court twice affirmed and twice remanded for resentencing at a new penalty phase. At Petitioner's third penalty phase, he was sentenced to death, and the Supreme Court affirmed. At issue was Petitioner's third successive motion for postconviction relief under Fla. R. Crim. P. 3.851, filed on May 10, 2019. The circuit court dismissed the petition as untimely under rule 3.851(d)(2)(B). The Supreme Court affirmed without addressing the ruling that Petitioner's motion was untimely, holding that the record conclusively refuted Petitioner's allegation that trial counsel conceded Petitioner's guilt at trial. View "Merck v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court summarily denying Appellant's successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the postconviction court properly denied relief.Specifically, the Supreme Court held (1) Appellant was not entitled to postconviction relief based on his intellectual disability claim because Hall v. Florida, 572 U.S. 701 (2014), does not apply retroactively; and (2) Appellant was not entitled to relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016) because, during Appellant's trial, the requirement that a jury unanimously find a statutory aggravating circumstance beyond a reasonable doubt was satisfied. View "Poole v. State" on Justia Law