Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the postconviction court denying Appellant's claim of ineffective assistance of counsel for failure to challenge a biased juror, holding that the postconviction court's finding that defense counsel had a reasonable, strategic basis for not challenging the juror was supported by competent, substantial evidence.Appellant was convicted of first-degree murder, kidnapping, and robbery. Appellant was sentenced to death for the murder. Appellant later filed a motion for postconviction relief, alleging, among other things, ineffective assistance of counsel for failure to challenge a biased juror. After the Supreme Court remanded the issue for an evidentiary hearing, the postconviction court denied the claims, finding that counsel had chosen not to challenge the juror as part of a reasonable trial strategy. The Supreme Court affirmed, holding that competent, substantial evidence supported the finding that counsel made a reasonable decision not to challenge the juror; and (2) this strategy was objectively reasonable from the perspective of believing that it would operate to Defendant's advantage in this particular trial. View "Patrick v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the trial court properly denied relief.In his postconviction motion, Appellant raised a claim relating to the legal name of one of his victims, to whom he had been married, and sought relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 S. 3d 40 (Fla. 2016). The trial court denied the motion. The Supreme Court affirmed, holding (1) Appellant's claim regarding the legal name of one of his victims was untimely and procedurally barred; and (2) Hurst relief did not apply to Appellant because he waived his right to a penalty phase jury. View "Valentine v. State" on Justia Law

The Supreme Court quashed the decision of the Fourth District Court of Appeal, holding that the party opposing a peremptory strike must make a specific objection to the proponent's proffered race-neutral reason for the strike, if the strike is contested, to preserve a claim that the trial court erred in concluding that the proffered reason was genuine.At issue was the proper procedure for preserving a challenge to the trial court's determination that the facially race-neutral reason proffered by the proponent of a peremptory strike was genuine under step three of Melbourne v. State, 679 So. 2d 759 (Fla. 1996). During the voir dire proceedings in Defendant's case, Defendant objected to the State's peremptory strike as to a prospective African-American juror but never argued that the State's proffered explanation was not genuine. The Fourth District reversed and remanded for a new trial, concluding that the trial court had failed to demonstrate compliance with the duty to determine the genuineness of the proffered race-neutral reason. The Supreme Court quashed the Fourth District's decision, holding that because Defendant did not make a specific objection to the State's proffered facially race-neutral reason for the strike Defendant failed to preserve his challenge to the trial court's step three genuineness determination. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that Walls v. State, 213 So. 3d 340 (Fla. 2016), is no longer good law.In 1998, Appellant was convicted of murder and sentenced to death. In 2006, Appellant sought postconviction relief on his claim that he was intellectually disabled and, therefore, constitutionally ineligible for the death penalty. The postconviction court denied relief, and the Supreme Court affirmed. In the instant postconviction petition, Appellant sought another determination of his intellectual disability. Appellant relied in part on the Supreme Court's decision in Walls v. State, in which the Court held that the United States Supreme Court's decision in Hall v. Florida, 472 U.S. 701 (2014), is retroactive to cases where there has already been a finding that the defendant is not intellectually disabled. The Supreme Court affirmed, holding (1) this Court in Walls clearly erred in concluding that Hall applies retroactively, and this Court should not continue to apply the erroneous reasoning of Walls; and (2) therefore, the circuit court did not err in denying relief. View "Phillips v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree felony murder, robbery with a firearm, aggravated assault with a firearm, and burglary of a dwelling with an assault or battery while armed with a firearm and Defendant's sentence of death, holding that Defendant was not entitled to reversal on any of his allegations of error.Specifically, the Supreme Court held (1) the trial court did not err in finding that the State did not commit a discovery violation regarding a certain photograph; (2) the trial court did not err in admitting two photographs over an objection for lack of proper predicate and prejudicial impact; (3) the trial court did not abuse its discretion in denying Defendant's motions for mistrial; (4) the trial court did not err in allowing the State to argue during the penalty phase that Defendant possessed and discharged a firearm; (5) the penalty phase closing arguments did not violate Defendant's constitutional rights; (6) the penalty phase jury instructions and verdict form were proper; (7) the trial court’s sentencing order was legally deficient and incorrect as a matter of law; (8) there was sufficient evidence to sustain the conviction; and (9) Defendant's death sentence was proportionate. View "Smiley v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree murder and burglary of a dwelling with an assault and while armed with a firearm and Defendant's sentence of death, holding that this Court now joins federal courts and the majority of state courts in abandoning a special appellate standard to evaluate evidence on appeal in a wholly circumstantial case rather than in a case with some direct evidence.Defendant's convictions in this case were wholly based upon circumstantial evidence. The Supreme Court affirmed the convictions and sentence after discontinuing the use of the special standard of review previously applied to wholly circumstantial cases, holding (1) the standard of review now to be used in all cases where the sufficiency of the evidence is analyzed is whether the State presented competent, substantial evidence to support the verdict; (2) in this case, a rational trier of fact could have found the existence of the elements of the crime beyond a reasonable doubt; and (3) Defendant was not entitled to reversal of his convictions on any of his remaining allegations of error. View "Bush v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's claim of intellectual disability, raised in successive motions for postconviction relief under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in denying relief.Appellant was convicted of first-degree murder and sentenced to death in two separate cases. After the United States Supreme Court decided Hall v. Florida, 572 U.S. 701 (2014), Appellant filed successive motions for postconviction relief in both of his capital cases, asserting that the circuit court's denials of his previous claims of intellectual disability were based on the court's improper interpretation of Florida's intellectual disability statute. The circuit court summarily denied the motions. The Supreme Court reversed and remanded for an evidentiary hearing on the issue of intellectual disability. After a hearing, the circuit court denied the claim. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Appellant's intellectual disability claim; and (2) Appellant was not entitled to relief under Hurst v. Florida, 136 S. Ct. 616 (2016), or Hurst v. State, 202 So. 3d 40 (Fla. 2016). View "Franqui v. State" on Justia Law

The Supreme Court denied the instant mandamus petition filed by Hicks and sanctioned Hicks by barring him from filing any further pro se requests for relief related to his criminal case.Hicks was convicted of one count of lewd and lascivious conduct by a person over eighteen years of age on a victim under sixteen years of age. Since 2016, Hicks filed thirteen pro se requests for relief in the Supreme Court related to his criminal case. The Court did not grant the relief sought in any of Hicks' filings. In the instant petition, Hicks sought a writ of mandamus compelling the circuit court to comply with the requirements of Fla. R. Crim. P. 3.850 by filing a copy of an order denying his second postconviction motion with the clerk of court. The Supreme Court dismissed the petition and found that Hicks abused this Court's limited judicial resources. The Court directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Hicks that are related to his criminal case, unless such filings are signed by a member of The Florida Bar in good standing. View "Hicks v. State" on Justia Law

The Supreme Court held that Jay Barringer's quo warranto petition filed in this case was a frivolous proceeding brought before the Supreme Court by a state prisoner and sanctioned Barringer by barring him from filing any further pro se requests for relief related to his criminal case.Barringer was convicted of one count of attempted sexual battery of a victim less than twelve years old and sentenced to twenty-five-years' imprisonment. In 2011, Barringer began filing petitions in the Supreme Court. The Court did not grant the relief sought in any of Barringer's filings. In the instant quo warranto petition Barringer challenged his conviction on the ground that the information was defective, a claim Barringer previously raised by way of a habeas petition. The Supreme Court denied the petition and found that Barringer abused the Court's limited judicial resources. The Court sanctioned Barringer by directing the Clerk of Court to reject any future pleadings or other requests for relief submitted by Barringer that are related to his criminal case, unless such filings are signed by a member of The Florida Bar in good standing. View "Barringer v. Halkitis" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's successive motion to vacate his sentence of death under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in denying the Rule 3.851 motion.Appellant was convicted of first-degree murder, armed robbery, and grand theft. Appellant was sentenced to death for the murder. The Supreme Court affirmed the convictions but reversed Appellant's death sentence and remanded the case for a new penalty phase. After a new penalty phase, Appellant was again sentenced to death. In his successive Rule 3.851 motion, Appellant raised three claims. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court (1) properly denied Appellant's claim that his death sentence violated the Sixth and Eighth Amendments in light of Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016); (2) correctly denied Appellant's claim that his sentence violated the Eighth Amendment; and (3) did not err in denying Appellant's claim of newly discovered evidence. View "Archer v. State" on Justia Law