Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed the circuit court’s denial of Appellant’s motion to vacate sentences of death under Fla. R. Crim. P. 3.851. The jury in Appellant’s case unanimously recommended death. In this successive postconviction motion, Appellant argued that his death sentences violated the Sixth Amendment in light of Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), and Hurst v. Florida, 136 S. Ct. 616 (2016) and that his death sentences violated the Eighth Amendment under Caldwell v. Mississippi, 472 U.S. 320 (1985), and must be vacated in light of Hurst, Hurst v. Florida, and Perry v. State, 210 So. 3d 630 (Fla. 2016). The circuit court denied relief. The Supreme Court affirmed, holding (1) the Hurst error in this case was harmless beyond a reasonable doubt; (2) Hurst-induced Caldwell claims against the standard jury instruction do not provide an avenue for Hurst relief; and (3) the circuit court properly denied Appellant’s Eighth Amendment Caldwell claim. View "Reynolds v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s order summarily denying Appellant’s first successive postconviction motion filed under Fla. R. Crim. P. 3.851.Appellant was convicted of first-degree murder, kidnapping, robbery, sexual battery, and burglary of a conveyance with assault. The trial court sentenced Appellant to death following a unanimous jury recommendation for death. In the instant successive postconviction motion, Appellant claimed that he was entitled to relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court affirmed the postconviction court’s denial of relief, holding that the Hurst error in this case was harmless beyond a reasonable doubt. View "Johnston v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s order denying Appellant’s motion to vacate judgments of conviction, including his conviction for first-degree murder, and his sentence of death under Fla. R. Crim. P. 3.851.Following a jury's unanimous recommendation for death, the trial court sentenced Appellant to death. The Supreme Court affirmed. In this successive postconviction motion, Appellant claimed that he was entitled to relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). The postconviction court denied relief. The Supreme Court affirmed, holding that Hurst was applicable in Appellant’s case, but the Hurst error here was harmless beyond a reasonable doubt. View "Tanzi v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Appellant’s successive motion for postconviction relief seeking relief based on Hurst v. Florida, 136 S. Ct. 616 (2016), Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), and Perry v. State, 210 So. 3d 630 (Fla. 2016).Appellant was convicted of first-degree murder and kidnapping with intent to commit or facilitate the commission of a homicide. The jury unanimously recommended death. On direct appeal, the Supreme Court affirmed Appellant’s first-degree murder conviction but reversed the judgment of guilt of kidnapping and remanded for entry of judgment for false imprisonment. Appellant’s sentence of death became final in 2005. On appeal from the denial of his postconviction motion, Appellant argued that the Hurst error in his case was not harmless beyond a reasonable doubt even where the jury unanimously recommended death. The Supreme Court disagreed, holding that the Hurst error in Appellant’s case was harmless beyond a reasonable doubt. View "Crain v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s order vacating Appellee’s sentence of death and granting Appellee a new penalty phase, holding that the Hurst error in Appellee’s case was not harmless beyond a reasonable doubt.Appellee was convicted of first-degree murder, kidnapping, and capital sexual battery and sentenced to death. The jury recommended a death sentence by a vote of ten to two. The Supreme Court affirmed the convictions and sentence. Appellee’s death sentence became final in 2011. After the issuance of Hurst v. Florida, 136 S. Ct. 616 (2016), Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), and its progeny, Appellee filed a successive motion to vacate death sentence. The postconviction court granted the motion with regard to the claim that Appellee was entitled to a new penalty phase. The Supreme Court affirmed, holding that because the jury did not make the requisite factual findings under Hurst and did not unanimously recommend a sentence of death, the Hurst error in Appellee’s case was not harmless beyond a reasonable doubt. View "State v. Smith" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Appellant’s successive postconviction motion to vacate a sentence of death under Fla. R. Crim. P. 3.851. In his successive motion, Appellant claimed that his death sentence violated the Sixth Amendment in light of Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), and Hurst v. Florida, 136 S. Ct. 616 (2016) and violated the Eighth Amendment under Caldwell v. Mississippi, 472 U.S. 320 (1985). The Supreme Court affirmed the circuit court’s order summarily denying Appellant’s successive motion for postconviction relief, holding (1) any Hurst error in this case was harmless beyond a reasonable doubt; and (2) Appellant’s Caldwell claim was procedurally barred because it was raised and rejected on direct appeal. View "Taylor v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order summarily denying Defendant’s first successive motion for postconviction relief, holding that any Hurst error in this case was harmless beyond a reasonable doubt.In 1998, a jury convicted Defendant of two counts of first-degree murder. The jury unanimously recommended the death sentence for each murder by a vote of twelve to zero. The Supreme Court affirmed the convictions and death sentences on direct appeal. In 2017, Defendant filed his first successive postconviction motion in which he raised numerous claims in light of Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court summarily denied Defendant’s successive postconviction motion. The Supreme Court affirmed, holding that any Hurst error was harmless. View "Smithers v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order summarily denying Appellant’s first successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that any Hurst error in this case was harmless beyond a reasonable doubt.In 2000, a jury convicted Appellant of first-degree murder and sexual battery upon a person twelve years of age or older with use of a deadly weapon. The jury unanimously recommended the death sentence by a vote of twelve to zero. The Supreme Court affirmed Appellant’s convictions and death sentence on direct appeal. In 2016, Appellant filed his first successive postconviction motion arguing that he was entitled to relief based on Hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). The circuit court summarily denied Appellant’s successive postconviction motion. The Supreme Court affirmed, holding that any Hurst error in this case was harmless beyond a reasonable doubt. View "Grim v. State" on Justia Law

The Supreme Court affirmed the orders of the circuit court denying Ronnie Johnson’s motions filed under Fla. R. Crim. P. 3.851 seeking 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). Johnson was sentenced to death for one murder conviction following a jury’s recommendation for death by a vote of seven to five. Johnson was also sentenced to death for a second murder following a jury’s recommendation for death by a vote of nine to three. Both of Johnson’s death sentences became final in 1998. In affirming the denial of Johnson’s motions, the Supreme Court held that Hurst did not apply retroactively to Johnson’s sentences of death. View "Johnson v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Appellant’s motion filed under Fla. R. Crim. P. 3.851 in which 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). Appellant was sentenced to death following a jury’s recommendation for death by a vote of eight to four, and his sentence of death became final in 2001. In affirming, the Supreme Court held that Hurst did not apply retroactively to Appellant’s sentence of death and, accordingly, affirmed the denial of Appellant’s motion. View "Gonzalez v. State" on Justia Law