Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the circuit court denying Appellant’s successive motion for postconviction relief, holding that Mullens v. State, 197 So. 3d 16 (Fla. 2016) controlled the outcome of this case.Appellant pleaded guilty to first-degree murder and, after a second penalty phase, was sentenced to death. The Supreme Court affirmed. Appellant later filed a successive motion to vacate his sentence of death pursuant to Fla. R. Crim. P. 3.851. The postconviction court summarily denied the motion. The Supreme Court affirmed, holding (1) Appellant was not entitled to retroactive application of Hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), because his conviction and sentence became final more than two years before Ring was issued; and (2) Appellant’s claim regarding his right to a penalty-phase jury was procedurally barred because it should have been raised on direct appeal. View "Robinson v. State" on Justia Law

The Supreme Court dismissed Petitioner’s petition for writ of habeas corpus and directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner that are related to Petitioner’s criminal cases unless such filings are signed by a member in good standing of The Florida Bar, holding that Petitioner had abused the Supreme Court’s limited judicial resources.Petitioner filed twenty-nine petitions or notices with the Supreme Court since September 17, 2008. On September 12, 2018, the Supreme Court dismissed Petitioner’s petition for writ of habeas corpus and ordered Petitioner to show cause why he should not be barred from filing further pro se requests for relief in this Court. The Supreme Court found that Petitioner failed to show cause why he should not be barred from filing further pro se requests for relief in the Supreme Court, holding that Petitioner’s extensive history of filing pro se petitions and requests for relief that were meritless or otherwise inappropriate for the Supreme Court’s review required that Petitioner be barred. View "Marts v. Jones" on Justia Law

The Supreme Court affirmed the orders of the trial court partially granting and partially denying Gerald Delane Murray’s initial motion for postconviction relief under Fla. R. Crim. P. 3.851 and denying Murray’s successive postconviction motion, and further denied Murray’s petition for a writ of habeas corpus, holding that Murray was not entitled to relief on any of his claims on appeal.Murray was convicted of first-degree murder and sentenced to death after four trials and three convictions. The Supreme Court affirmed. Thereafter, Murray filed a motion for postconviction relief that was amended four times. The postconviction court granted a new penalty phase pursuant to Hurst but denied relief on all other claims. The postconviction court summarily denied relief on Appellant’s successive motion for postconviction relief. The Supreme Court affirmed, holding (1) the trial court did not err by granting Murray a new penalty phase pursuant to Hurst; (2) the trial court properly denied Murray’s other initial postconviction motion claims; (3) the summary denial of Appellant’s successive postconviction motion was not in error; and (4) Appellant was not entitled to habeas relief on any of his claims. View "State v. Murray" on Justia Law

The Supreme Court approved of the decision of the Second District Court of Appeal in this case concerning the proper interpretation of Florida’s witness tampering statute, Fla. Stat. 914.22, holding that the statute does not require the State to establish that the witness attempted to contact law enforcement during the commission of the underlying criminal offense.The central issue was whether section 914.22(1)(e) requires the State to demonstrate that a witness attempted to contact law enforcement to prove its case in chief on witness tampering. The Supreme Court held (1) the statute does not designate an attempt to contract law enforcement as an element of the crime of witness tampering; and (2) in the instant case, the State presented competent, substantial evidence to support Defendant’s conviction for witness tampering. View "McCloud v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s denial of Appellant’s successive motion for postconviction relief from a sentence of death, holding that any error in the proceedings below was harmless.Appellant was convicted of first-degree murder and sentenced to death. After unsuccessfully filing his successive motion to vacate a sentence of death under Fla. R. Crim. P. 3.851 Appellant filed this appeal. The Supreme Court affirmed, holding (1) it was reasonable for the postconviction court to deny Appellant’s motion to exceed page limit; (2) the postconviction court did not violate Appellant’s due process rights by failing to hold a case management conference, pursuant to Huff v. State, 622 So. 2d 982 (Fla. 1993), before ruling on his second successive motion for postconviction relief; and (3) Appellant’s remaining claims were meritless. View "Rivera v. State" on Justia Law

The Supreme court affirmed the circuit court’s order granting in part and denying in part Appellant’s motion for DNA testing under Fla. R. Crim. P. 3.853, holding that none of Appellant’s claims on appeal had merit.After a retrial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed on direct appeal. Appellant later filed his motion for DNA testing of evidence pursuant to Rule 3.853. After an evidentiary hearing, the circuit court granted the motion in part and denied it in part. Appellant appealed the circuit court’s partial denial of his Rule 3.853 motion. The Supreme Court affirmed, holding (1) the circuit court did not err in adopting the State’s reasoning and conclusions as to Appellant’s motion in its order; and (2) the partial denial of Appellant’s motion did not violate his Fifth, Eighth, or Fourteenth Amendment rights. View "Gosciminski v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant’s motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the circuit court did not err or abuse its discretion.Appellant was convicted of kidnapping and first-degree murder and sentenced to death. After Appellant’s death sentence became final Appellant filed her motion for postconviction relief, raising fourteen claims and then amending the motion to add a Hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State, 202 So. 3d 40 (Fla. 2016) claim. The trial court denied the motion in its entirety. The Supreme Court affirmed, holding that Appellant was not entitled to relief on her claims alleging ineffective assistance of counsel, a Giglio violation, and a Hurst error. View "Allen v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Appellant’s guilt phase claims, vacating his sentence of death, and remanding this case for a new penalty phase based on Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), holding that the postconviction court did not err or abuse its discretion.After a jury trial, Appellant was convicted of first-degree murder and other offenses. The trial court followed the jury’s recommendation and sentenced Appellant to death. Appellant later filed a motion to vacate his first-degree murder conviction and sentence of death pursuant to Fla. R. Crim. P. 3.851, raising eight claims for relief. The postconviction court denied Appellant’s guilt phase claims but vacated his sentence of death and granted a new penalty phase pursuant to Hurst. The Supreme Court affirmed, holding that none of Appellant’s claims of ineffective assistance of counsel had merit because either deficiency or prejudice or both was not established. View "King v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s order denying Appellant’s motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief.Appellant was convicted of two counts of first-degree murder and sentenced to death following the jury’s recommendation for death for both murders by a vote of ten to two. The sentences of death became final in 1993. In his postconviction motion, Appellant sought relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and this Court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). The Supreme Court affirmed the denial of relief, holding that Hurst did not apply retroactively to Appellant’s sentences of death. View "Jones v. State" on Justia Law

The Supreme Court affirmed the denial of Appellant’s motion filed pursuant to Fla. R. Criminal. P. 3.851, holding that this Court’s prior denial of Appellant’s postconviction appeal raising similar claims was a procedural bar to the claim at issue in this appeal.Appellant’s motion sought relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and the Supreme Court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). The circuit court denied relief. The Supreme Court affirmed, holding that, even if his motion was not procedurally barred, Appellant was not entitled to relief under Hurst or the legislation implementing the rights recognized in Hurst. View "Rodriguez v. State" on Justia Law