Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed the circuit court’s order denying Appellant’s fourth successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851 and denied relief based on Hurst v. Florida, 577 U.S. __ (2016), holding (1) the circuit court correctly found that Appellant was not eligible for the death penalty due to his alleged intellectual disability in light of the United States Supreme Court’s decision in Hall v. Florida, 572 U.S. __ (2014), because Appellant did not qualify as intellectually disabled under Florida law; and (2) because Appellant’s convictions and sentences became final in 1995 he was not entitled to relief under Hurst. View "Jones v. State" on Justia Law

The Supreme Court denied the petition for a writ of habeas corpus filed by Petitioner, a prisoner under a sentence of death for the murders of two victims. The court held (1) Petitioner was not entitled to a cumulative review of evidence supporting his alleged actual and legal innocence under due process principles; (2) Petitioner was not entitled to relief on his claim that he was denied his fundamental right to testify; and (3) Petitioner was not entitled to relief on his claim that he was unconstitutionally denied access to materials that may contain DNA evidence. View "Lambrix v. Jones" on Justia Law

The Supreme Court granted Petitioner’s petition for a writ of habeas corpus, vacated his sentence of death, and remanded for a new penalty phase, holding that Petitioner’s death sentence violated Hurst v. State, 202 So. 3d 40 (Fla. 2016).Petitioner was convicted and sentenced to death for two counts of first-degree murder. A jury recommended a sentence of death by a vote of eight to four. The trial court sentenced Petitioner to death for both murders. The Supreme Court concluded that the Hurst error that occurred during the penalty phase was not harmless beyond a reasonable doubt and that the matter must be remanded for a new penalty phase proceeding consistent with Hurst. View "Doorbal v. Jones" on Justia Law

Law enforcement officers may detain the passengers of a vehicle for the reasonable duration of a traffic stop without violating the Fourth Amendment.Defendant was one of two passengers in a vehicle stopped for a faulty taillight and a stop sign violation. Defendant was subsequently arrested for violation of probation. During the search incident to arrest, cocaine was recovered from Defendant’s pocket. Defendant filed a motion to suppress, arguing that he was illegally detained during the traffic stop. The circuit court denied the motion. The court of appeal affirmed, ruling that “an officer may, as a matter of course, detain a passenger during a lawful traffic stop without violating the passenger’s Fourth Amendment rights.” The Supreme Court approved the decision below, holding that the seizure of Defendant did not violate the Fourth Amendment. View "Presley v. State" on Justia Law

The trial court properly denied Petitioner’s request for a second-degree arson instruction as a lesser included offense of first-degree arson because the trial evidence did not entitle Defendant to such an instruction.A jury found Petitioner guilty of first-degree murder, arson, and robbery. The trial court sentenced Petitioner to life imprisonment for first-degree murder. The district court affirmed, rejecting Petitioner’s contention that he was entitled a jury instruction on second-degree arson of a structure. The Supreme Court affirmed, holding that the trial court properly denied Petitioner’s requested instruction because this case did not present the trial court with any evidence to support a second-degree arson instruction. View "Stevens v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree murder but vacated his sentence of death and remanded for a new penalty phase. The court held (1) the evidence was sufficient to support Defendant’s conviction; (2) the trial court did not abuse its discretion in excluding evidence of the victim’s drug use; (3) the trial court did not abuse its discretion by not conducting an inquiry into counsel’s effectiveness pursuant to Nelson v. State, 274 So. 2d 256 (Fla. 4th DCA 1973); (4) Defendant’s claim of ineffective assistance of counsel was not cognizable on direct appeal; (5) competent, substantial evidence supported the trial court’s finding that Defendant was not intellectually disabled; but (6) in light of a ten-to-two jury recommendation for death, error pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016), occurred in this case, and the error was not harmless beyond a reasonable doubt. View "Glover v. State" on Justia Law

Manslaughter is a category one lesser included offense of second-degree felony murder.The Fourth District Court of Appeal granted Defendant’s motion to certify to the Supreme Court the question of whether manslaughter is a necessarily lesser included offense of second-degree felony murder after Defendant appealed his conviction of second-degree felony murder and burglary. On appeal, Defendant argued that the trial court erred in denying his request for an instruction on manslaughter as a lesser included offense of second-degree felony murder. The Supreme Court answered the appellate court’s certified question in the affirmative, holding that manslaughter is a necessarily lesser included offense of second-degree felony murder. View "Dean v. State" on Justia Law

The Supreme Court denied the petition for a writ of quo warranto filed by Petitioner, the state attorney for Florida’s Ninth Judicial Circuit, challenging Governor Rick Scott’s authority to reassign the prosecution of death penalty eligible cases in the Ninth Circuit to the state attorney for Florida’s Fifth Judicial Circuit. The Governor reassigned the prosecution of death penalty eligible cases pending in the Ninth Circuit after Petitioner announced her intent to implement a blanket policy of not seeking the death penalty in any eligible case. The Supreme Court held that the Governor did not abuse his discretion in reassigning the cases at issue to the state attorney for Florida’s Fifth Judicial Circuit pursuant to Fla. Stat. 27.14. View "Ayala v. Scott" on Justia Law

The Supreme Court reversed Defendant’s sentences of death imposed for his convictions of first-degree murder and remanded for a new penalty phase based on Hurst v. State, 202 So. 3d 40 (Fla. 2016) and Mosley v. State, 209 So. 3d 1248 (Fla. 2016), holding that the jury’s nonunanimous recommendation of death by a vote of seven to five as to both murders was not harmless beyond a reasonable doubt. The court thus reversed the postconviction court’s order denying postconviction relief as to the penalty phase of Defendant’s trial but affirmed the postconviction court’s order denying postconviction relief as to the guilt phase. The court also denied Defendant’s habeas petition to the extent he sought relief pursuant to Hurst and affirmed the postconviction court’s denial of Defendant’s successive motion to vacate judgment and sentence. View "Gregory v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions and death sentences for the first-degree murders of a mother and her two children. The court held (1) the trial court did not err in concluding that the “particularly vulnerable” aggravator was proven beyond a reasonable doubt as to the murders of the two children; (2) the trial court did not err in finding that the especially heinous, atrocious, or cruel aggravator applied to one of the children’s murder; (3) Defendant’s challenges to the sufficiency of the sentencing order were unavailing; (4) any error in the trial court’s failure to consider parole ineligibility as a mitigating circumstance was harmless beyond a reasonable doubt; (5) Defendant’s guilty pleas were knowingly, intelligently, and voluntarily entered; (6) the death sentences were proportionate; and (7) Defendant was not entitled to relief under Hurst v. Florida, 577 U.S. __ (2016). View "Covington v. State" on Justia Law