Justia Florida Supreme Court Opinion Summaries

In this case, the defendant was found guilty by a jury of being a violent career criminal (VCC) in possession of a firearm, following an incident in which he brandished and fired a gun during an argument. To establish his VCC status, the State relied on three prior convictions: aggravated battery, burglary, and escape. While the defendant did not contest the first two convictions as qualifying offenses, he argued that his 1995 escape conviction, which arose from an escape from a juvenile detention facility, should not count as a predicate offense under the VCC statute.On direct appeal, the Florida Second District Court of Appeal agreed with the defendant that the juvenile escape conviction was not a qualifying offense under the VCC statute. However, the court affirmed the conviction because the defendant had not preserved this argument at trial, and the error was not considered “fundamental” under the standard set by the Supreme Court of Florida in F.B. v. State. The Second District found that, since the evidence at trial established at least the lesser included offense of felon in possession of a firearm, the error did not reach the level of fundamental error requiring reversal.The Supreme Court of Florida reviewed the case due to a conflict with other district courts on the issue of fundamental error in evidence insufficiency cases. The Court ultimately held that the defendant’s 1995 juvenile escape conviction does qualify as a predicate offense for VCC status. The Court reasoned that the relevant statutes expressly state that escape from a juvenile facility constitutes escape within the meaning of the adult escape statute, and the legislative scheme supports treating such convictions as qualifying offenses. Accordingly, the Supreme Court of Florida approved the judgment affirming the defendant’s conviction. View "Pryor v. State of Florida" on Justia Law

In 1990, the defendant was convicted of first-degree murder, kidnapping, and robbery after abducting a woman from a bar, fatally stabbing her, and leaving her body by a dirt road. Physical evidence, including fingerprints, blood, and items from the bar found near his home, linked him to the crime. The jury recommended a death sentence, which the trial court imposed, finding multiple aggravating factors. The Florida Supreme Court affirmed his convictions and sentence on direct appeal.Over the following decades, the defendant filed numerous postconviction motions and habeas petitions, all of which were denied by various courts, including the Florida Supreme Court. In his third and fourth successive postconviction motions, he raised claims based on alleged newly discovered evidence, including declarations that a serial killer confessed to the murder, a witness’s willingness to recant, and purported evidence of prosecutorial misconduct. He also asserted claims under Jones v. State, Brady v. Maryland, Giglio v. United States, and Massiah v. United States, as well as a due process claim regarding a prior appellate decision. The Circuit Court for Walton County summarily denied all claims, finding most to be untimely or procedurally barred under Florida Rule of Criminal Procedure 3.851, and rejecting others on the merits.The Supreme Court of Florida reviewed the summary denial de novo and affirmed. The court held that the defendant’s claims were untimely and procedurally barred because he failed to demonstrate due diligence in discovering the alleged new evidence or to show that the claims could not have been raised earlier. The court also found that the purported new evidence was inadmissible or would not probably produce an acquittal at retrial. Additionally, the court concluded that the due process claim was meritless and that the circuit court correctly denied relief. The summary denials of the third and fourth successive postconviction motions were affirmed. View "Suggs v. State of Florida" on Justia Law

While serving a forty-year sentence at Mayo Correctional Institution, Jesse Bell and his cellmate planned and executed the murder of another inmate as a rehearsal for a subsequent planned attack on a correctional officer. On June 26, 2019, they killed the inmate and later that day attempted to kill the officer, who survived. Bell confessed to the crimes and was indicted for first-degree murder, attempted murder, conspiracy, and possession of contraband. Shortly after counsel was appointed, Bell waived his right to counsel and a penalty-phase jury, entered a no-contest plea, and represented himself during sentencing. The court found multiple aggravating factors and sentenced Bell to death.The Circuit Court for Lafayette County conducted the trial and sentencing. On direct appeal, the Supreme Court of Florida affirmed Bell’s conviction and death sentence, finding his waivers and plea were knowing and voluntary, and that he was not deprived of an individualized sentencing. Bell then filed a motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, arguing his waivers were involuntary due to prison abuse, that counsel was ineffective for not investigating this abuse, and that he was denied individualized sentencing. The circuit court summarily denied the motion, finding the claims procedurally barred or refuted by the record.The Supreme Court of Florida reviewed the summary denial and Bell’s habeas petition. The court held that Bell’s postconviction claims were procedurally barred because they could have been raised on direct appeal, and that the record showed his waivers were voluntary. The court also found no ineffective assistance of counsel or appellate counsel, as there was no evidence of prejudice or deficient performance. The order denying postconviction relief was affirmed, and habeas relief was denied. View "Bell v. State of Florida" on Justia Law

In 1982, Kayle Barrington Bates committed a series of violent crimes, including robbery, attempted sexual battery, and the murder of Janet Renee White. Bates was apprehended near the scene shortly after the attack, and physical evidence, as well as his own admissions, linked him to the crimes. He was charged with first-degree murder, kidnapping, attempted sexual battery, and armed robbery. A jury found him guilty on all counts and recommended a death sentence.After his initial conviction and sentencing, the Supreme Court of Florida affirmed the convictions but vacated the death sentence due to insufficient evidence supporting two aggravating factors, remanding for resentencing. On remand, the trial court again imposed the death penalty, which the Supreme Court of Florida affirmed. Bates pursued multiple rounds of postconviction relief in both state and federal courts, raising various constitutional and evidentiary claims, all of which were denied. His most recent efforts included a fourth successive postconviction motion and a petition for a writ of habeas corpus, following the signing of a new death warrant.The Supreme Court of Florida, exercising its mandatory review jurisdiction, affirmed the circuit court’s summary denial of Bates’ fourth successive postconviction motion and the denial of his public records requests. The court found Bates’ claims to be untimely, procedurally barred, or previously litigated and rejected. The court also denied his habeas petition, finding all claims either procedurally barred or without merit. The court denied Bates’ requests for a stay of execution and oral argument, and ordered that no motion for rehearing would be considered, with the mandate to issue immediately. The main holding is that Bates is not entitled to postconviction or habeas relief, and his execution may proceed. View "Bates v. State" on Justia Law

Edward J. Zakrzewski, II, was sentenced to death for the murders of his wife, Sylvia, and two minor children, Edward and Anna, which he committed on June 9, 1994. Zakrzewski pled guilty to all three murders and was sentenced to death for each, with the trial court overriding the jury's recommendation of life imprisonment for Anna's murder. The trial court found three aggravating factors for each murder and gave significant weight to both statutory and nonstatutory mitigators.On direct appeal, the Florida Supreme Court affirmed Zakrzewski’s convictions and sentences. The United States Supreme Court denied certiorari review, making the sentences final. Over the next three decades, Zakrzewski sought postconviction relief multiple times in both state and federal courts, all of which were denied. His federal habeas petition was denied by the Northern District of Florida, and the Eleventh Circuit Court of Appeals affirmed the denial. Zakrzewski also filed several motions for postconviction relief under Florida Rule of Criminal Procedure 3.851, all of which were denied by the Florida Supreme Court.Governor Ron DeSantis signed Zakrzewski’s death warrant on July 1, 2025, setting an execution date of July 31, 2025. Zakrzewski filed his fifth successive motion for postconviction relief, raising three claims, which the Circuit Court of the First Judicial Circuit summarily denied. Zakrzewski appealed the denial, raising four arguments.The Supreme Court of Florida affirmed the circuit court’s summary denial of Zakrzewski’s fifth successive postconviction motion. The court found Zakrzewski’s claims untimely, procedurally barred, and meritless. The court also rejected Zakrzewski’s claims regarding the Governor’s discretion in signing death warrants and the lack of a recent clemency review. Additionally, the court upheld the circuit court’s denial of Zakrzewski’s requests for public records, finding no abuse of discretion. The court denied Zakrzewski’s motion for a stay of execution and request for oral argument. View "Zakrzewski v. State" on Justia Law

A defendant was convicted of first-degree felony murder, aggravated child abuse, and sexual battery following the 1992 death of a two-year-old child. The evidence at trial showed that the defendant was alone with the victim, who was later found unconscious, with visible injuries and blood present in the apartment and on the defendant’s clothing. The medical examiner concluded the cause of death was a cerebral hemorrhage from multiple blows to the head. The defendant claimed the child’s injuries were accidental or caused by another individual, but the jury rejected this defense and recommended a death sentence, which was imposed.After the conviction and sentence were affirmed by the Supreme Court of Florida, the defendant filed several postconviction motions and habeas petitions, all of which were denied. In the most recent proceedings, the defendant filed a fourth successive motion for postconviction relief in the Circuit Court for Duval County. The motion argued that microscopic slides from the autopsy constituted newly discovered evidence and that the State had suppressed exculpatory information in violation of Brady v. Maryland. The circuit court summarily denied the motion, finding the claims untimely and without merit, noting that the existence of the slides and the finding of pneumonia were disclosed in the original autopsy report and available to the defense.On appeal, the Supreme Court of Florida reviewed the summary denial de novo. The court held that both the Brady and newly discovered evidence claims were untimely because the defendant knew or could have known of the evidence with due diligence. The court further held that no evidence was suppressed and that the new expert’s conclusions did not meet the standards for materiality or probability of acquittal required for relief. The court affirmed the summary denial of postconviction relief. View "Davis v. State of Florida" on Justia Law

An individual was convicted of the 2010 first-degree felony murder of an elderly woman, Janet Patrick, after being seen with her at a grocery store and later found in possession of her car and credit cards. The victim’s body was discovered in a wooded area, and forensic evidence linked the defendant to the crime scene and the victim’s vehicle. The defendant was also charged with robbery and kidnapping. His defense at trial was based on claims of mental illness or seizures. The jury found him guilty on all counts.The Florida Supreme Court previously affirmed the convictions and non-capital sentences but reversed the death sentence because the jury’s recommendation was not unanimous, as required by Hurst v. State. After subsequent legal developments, including State v. Poole and State v. Okafor, the defendant was granted a new penalty phase. During the new penalty phase, the defendant represented himself, waived a jury trial, and declined to present mitigation evidence. The trial court denied his motion for a continuance to secure a new mitigation specialist, finding that he had been given multiple opportunities to obtain such assistance. The court ultimately sentenced him to death, finding four aggravating factors and several mitigating circumstances.On direct appeal, the Supreme Court of Florida reviewed four claims: denial of the motion to continue, voluntariness of waivers of jury and mitigation, access to discovery, and the constitutionality of Florida’s death penalty scheme. The court held that the trial court did not abuse its discretion in denying the continuance, that the waivers were knowing and voluntary, that discovery obligations were met, and that the capital sentencing scheme was constitutional. The court affirmed the sentence of death. View "Williams v. State of Florida" on Justia Law

In 2009, Timothy W. Fletcher was convicted of first-degree murder for the death of Helen Googe. Fletcher and his cellmate, Doni Ray Brown, escaped from jail and went to Googe’s home to steal money. Fletcher confessed to his involvement, although he initially claimed Brown was the primary aggressor. The physical evidence, including DNA under Googe’s fingernails, linked Fletcher to the crime. The jury found Fletcher guilty and recommended the death penalty by a vote of eight to four.Fletcher’s initial death sentence was vacated due to a non-unanimous jury recommendation, and he was granted a new penalty phase under Hurst v. State. During the new penalty phase, the State presented evidence to support four aggravating factors, while Fletcher presented evidence of forty-nine mitigating circumstances. The jury unanimously found all four aggravating factors and recommended the death penalty. The trial court merged two aggravators and found three aggravating factors, giving them great weight, and considered fifty-two mitigating factors, giving moderate weight to the cumulative mitigation.Fletcher appealed to the Supreme Court of Florida, raising nine issues, including claims of prosecutorial misconduct, jury nullification, and the constitutionality of Florida’s capital sentencing scheme. The court found no reversible error, concluding that the prosecutor’s comments did not improperly denigrate mitigating evidence, the jury followed instructions, and the victim impact evidence was admissible. The court also rejected Fletcher’s constitutional challenges to the death penalty statute and the aggravating factors applied in his case. The court affirmed Fletcher’s death sentence, finding that the trial court properly weighed the aggravating and mitigating factors and that the jury’s recommendation was supported by the evidence. View "Fletcher v. State of Florida" on Justia Law

A woman’s nude body was discovered near the Vaca Cut Bridge in Marathon, Florida, with evidence of ligature strangulation and severe sexual injuries. Car parts found near the body matched damage to a conversion van driven by Steven Wolf, who was detained nearby. Wolf gave inconsistent statements to law enforcement, initially denying involvement but later admitting to being present when the victim died in his van and to disposing of evidence. Forensic evidence, including DNA, linked Wolf to the victim and the crime scene. The medical examiner determined the victim was alive during the infliction of fatal injuries, which could not have been caused by male genitalia, and that she suffered extreme pain before death.Wolf was charged in the Circuit Court with first-degree murder, two counts of sexual battery with force likely to cause injury, and tampering with physical evidence. He was found guilty on all counts by a jury. During the penalty phase, the State presented evidence of Wolf’s prior violent felony conviction. The jury unanimously found all aggravating factors proven and recommended a death sentence. The trial court agreed, finding the aggravating factors outweighed the mitigating circumstances and sentenced Wolf to death.On direct appeal, the Supreme Court of Florida reviewed Wolf’s claims, including challenges to venue, jury selection, evidentiary rulings, prosecutorial misconduct, jury instructions, and the sufficiency of the evidence. The court held that venue was properly established in Monroe County, the trial court did not abuse its discretion in jury selection or evidentiary rulings, and the improper prosecutorial comments did not rise to fundamental error. The court also found sufficient evidence supported the convictions and the especially heinous, atrocious, or cruel aggravator. The Supreme Court of Florida affirmed Wolf’s convictions and sentence of death. View "Wolf v. State of Florida" on Justia Law

The appellant was married to the victim, with whom he shared two daughters, and was also living with her two sons from a previous marriage. In July 2019, following an argument, he killed his wife by beating her with a baseball bat and concealed her body in their home. Over the following weeks, he lied to family and friends about her whereabouts, impersonating her in communications. As the children returned home before the start of school, he became concerned that the boys might reveal their mother’s absence. He then killed the two boys, one by strangulation and the other by drowning, and later killed his two daughters in a similar manner. He concealed all five bodies in storage boxes, eventually transporting them in a minivan. After a wellness check was requested by the victim’s family, law enforcement began investigating. The appellant fled the state, ultimately confessing to the murders after a car accident in Georgia, and led police to the children’s remains.A grand jury in Marion County, Florida, indicted the appellant on four counts of first-degree murder (for the children) and one count of second-degree murder (for his wife). He pleaded guilty to all charges. At the penalty phase, the State sought six aggravating factors for each first-degree murder count. The defense presented expert testimony regarding the appellant’s mental health, arguing for mitigation. The trial court denied a defense request for a special jury instruction on the “avoid arrest” aggravator, gave the standard instruction, and the jury recommended death sentences. The court imposed four death sentences, finding all aggravators proven and that they outweighed mitigation.The Supreme Court of Florida reviewed the case, affirming the convictions and sentences. The court held that the trial court did not abuse its discretion in denying the special jury instruction, found Florida’s capital sentencing scheme constitutional, and determined the appellant’s guilty plea was knowingly, intelligently, and voluntarily entered. The convictions and death sentences were affirmed. View "Jones v. State of Florida" on Justia Law