Justia Florida Supreme Court Opinion Summaries

The Supreme Court denied Respondent's petition for a writ of mandamus and sanctioned Respondent, an inmate in state custody, by directing the clerk of court to reject any future pleadings or requests for relief submitted by Respondent related to his second-degree murder conviction unless such filings are signed by a member of The Florida Bar, holding that Respondent's petition was frivolous.Respondent was convicted of second-degree murder and sentenced as a habitual violent felony offender to life imprisonment. After the court of appeal affirmed, Respondent began demonstrating "a pattern of vexatious filing of meritless pro se requests for relief," including the instant mandamus petition. The Supreme Court denied the petition and directed Respondent to show cause why he should not be barred from filing any further pro se requests for relief. The Supreme Court then sanctioned Respondent, holding that Respondent had abused the Court's limited judicial resources. View "Calvin v. State" on Justia Law

The Supreme Court approved the decision of the Third District Court of Appeal concluding that Florida's extortion law, Fla. Stat. 836.05, requires the State to prove that the defendant made a threat "intentionally and without a lawful justification," holding that the lower court properly interpreted the statute.At issue was whether the State must prove that Defendant, who threatened to ruin the reputation of two fellow real estate brokers unless they paid him, made this threat with hatred for the complainants under section 836.05. While the Third District answered in the negative, the Fifth District Court of Appeal concluded that "maliciously" in section 836.05 required proof that Defendant acted with ill will or hatred. The Supreme Court approved the Third District's decision and disapproved the Fifth District's decision, holding that the trial court and court of appeal each decided correctly that the term "maliciously," as used in the statute, means "intentionally and without any lawful justification." View "Tomlinson v. State" on Justia Law

The Supreme Court affirmed the decisions of the circuit court denying Appellant's successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851 and Appellant's request for additional public records filed under Fla. R. Crim. P. 3.852(i), holding that there was no error.In 2012, Appellant was convicted of first-degree murder and sentenced to death. The circuit court later vacated Appellant's death sentence based on Hurst v. Stat, 202 So. 3d 40 (Fla. 2020), and ordered a new penalty phase. While Appellant's appeal in Calhoun II was pending, Appellant filed the successive postconviction motion at issue, raising a newly discovered evidence claim based on a purported jailhouse confession. On remand from Calhoun II, the circuit court denied Appellant's successive postconviction motion and his motion seeking additional public records. The Supreme Court affirmed the circuit court's denials of Appellant's successive postconviction motion and of his request for additional public errors, holding that the circuit court did not err or abuse its discretion. View "Calhoun v. State" on Justia Law

The Supreme Court affirmed Defendant's sentence of death imposed by the trial court following the Supreme Court's reversal of his original death sentence and remand for resentencing, holding that relative culpability review could not provide a basis for vacating Defendant's death sentence.Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court overturned the death sentence on the ground that the trial court improperly relied on extrarecord facts and remanded for the limited purposes of resentencing and a new sentencing order. On remand, the trial court again sentenced Defendant to death. On appeal, Defendant argued that relative culpability review required that his sentence be reduced to life imprisonment because his equally culpable codefendant was sentenced to life imprisonment by the same judge. At issue was whether relative culpability review survived Lawrence v. State, 308 So. 3d 544 (Fla. 2020). The Supreme Court affirmed, holding (1) this Court's relative culpability review was a corollary of its comparative proportionality review, which Lawrence held to be violative of the Florida Constitution; and (2) therefore, relative culpability review was rendered obsolete by the Lawrence decision and could not provide a basis for vacating Defendant's death sentence. View "Cruz v. State" on Justia Law

The Supreme Court denied Appellant's petition for a writ of habeas corpus, holding that Appellant failed to establish that he was entitled to the writ.Appellant was convicted in 1991, following a jury trial, of first-degree murder and kidnapping. Decades later, Appellant filed his petition for a writ of habeas corpus. In his petition, Appellant claimed that Chapter 2017-1, Laws of Florida, created a substantive right that must be retroactively applied under the state and federal Constitutions. The Supreme Court denied relief, holding that this Court had consistently rejected as without merit the claim that chapter 2017-1 created a substantive right that must be retroactively applied, and Appellant's arguments did not compel departing from precedent. View "Arbelaez v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's motions in this criminal case in which Appellant was under a death warrant, holding that Appellant was not entitled to relief.Defendant was convicted of the murders of two women and sentenced to death. The United States Supreme Court denied certiorari review in 1992. After the governor signed a death warrant for one murder and scheduled the execution for June 15, 2023 Appellant sought relief in the circuit court, without success. The Supreme Court affirmed, holding that the circuit court did not err in (1) summarily denying Defendant's fourth postconviction motion under Fla. R. Crim. P. 3.851; (2) denying Defendant's motion for competency determination; and (3) denying Defendant's motion for MRI and PET scan. The Court also denied Defendant's motion for stay of execution. View "Owen v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition for a writ of prohibition challenging the trial court's rulings in criminal cases and a separate civil case, holding that Petitioner failed to show cause why he should not be pro se barred for his repeated misuse of the Court's limited resources.Petitioner, an inmate whose most recent conviction was for possession of a controlled substance, began filing petitions in the Supreme Court in 2018 pertaining to several different criminal cases and a dependency case regarding his children. Petitioner filed the instant prohibition petition challenging the trial court's denial of a motion and seeking to dismiss the case. The Supreme Court denied the petition and directed Petitioner to show cause why he should not be barred from filing further pro se requests for relief. The Supreme Court then sanctioned Petitioner, holding that Petitioner had abused the Court's limited judicial resources. View "Hill v. State" on Justia Law

The Supreme Court denied Petitioner's petition for a writ of habeas corpus and then sanctioned him, holding that Petitioner failed to show cause why he should not be pro se barred.In 2006, Petitioner was sentenced to life imprisonment as a prison releasee reoffender on two counts of kidnapping, and the court of appeal affirmed. Since 2006, the Petitioner "engaged in a vexatious pattern of filing meritless requests for relief" in the Supreme Court pertaining to his convictions and sentences, none of which merited relief. In the instant habeas petition, Petitioner raised several claims relating to the circuit court's 2006 judgment and sentence. The Supreme Court denied the petition and directed Petitioner to show cause why he should not be barred from filing further pro se requests for relief. The Supreme Court sanctioned Petitioner as pro se barred, holding that Petitioner failed to show cause why he should not be sanctioned for his abusive conduct. View "Steiner v. Dixon" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of first-degree murder but set aside and his sentences of death for each murder, holding that Defendant was deprived of his right to "have the Assistance of Counsel for his defense" when the trial court put him to an improper choice at the beginning of the penalty phase proceedings.After the jury returned guilty verdicts for both first-degree murder charges the matter proceeded to the penalty phase. The jury unanimously recommended sentences of death. After a series of Spencer hearings, the trial court sentenced Defendant to death for each murder. The Supreme Court affirmed and remanded the case for a new penalty phase, holding (1) the trial court did not commit reversible error in its evidentiary rulings during Defendant's guilt phase proceedings; (2) Defendant's convictions were supported by competent, substantial evidence; but (3) Defendant's waiver of his right to counsel during the penalty phase was not knowing, intelligent, and voluntary, and Defendant was entitled to a new sentencing hearing based on the trial court's fundamental error in forcing him to abandon counsel during that phase. View "Figueroa-Sanabria v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding Defendant sane to be executed, holding that the record contained competent, substantial evidence to support the circuit court's determination that Defendant was sane to be executed.After considering all the evidence, the circuit court concluded that Defendant failed to establish by clear and convincing evidence that he was insane to be executed. The Supreme Court affirmed, holding that the circuit court (1) did not err in finding Defendant sane to be executed; and (2) did not abuse its discretion in denying Defendant's motion for a continuance. View "Owen v. State" on Justia Law