Justia Florida Supreme Court Opinion Summaries

The Supreme Court approved the decision of the court of appeal affirming the trial court's denial of Defendant's motion to suppress eyewitness identifications resulting from an out-of-court police procedure, holding that the proper standard of review is abuse of discretion review and that the court of appeal correctly analyzed the merits under that standard.In denying Defendant's motion to suppress, the court of appeal applied the abuse of discretion standard of review to the trial court's ruling on the out-of-court identification by the eyewitness. On appeal, the court of appeal affirmed "[d]ue to the abuse of discretion standard of review." The Supreme Court approved the decision below, holding (1) abuse of discretion review is the proper standard; and (2) the trial court did not abuse its discretion in admitting the out-of-court identification. View "Alahad v. State" on Justia Law

The Supreme Court dismissed Petitioner's pro se petition for writ of mandamus and sanctioned him for his repeated misuse of the judicial system's resources, holding that Petitioner's petition was frivolous.Petitioner was convicted of robbery with a weapon and trafficking in stolen property and sentenced to life in prison as a Prison Releasee Reoffender (PRR). The Third District Court of Appeal reversed Petitioner's PRR sentence and remanded the case with instructions to impose a "guideline sentence." Since then, Petitioner filed various filings related to his convictions and sentences, including this pro se mandamus petition. The Supreme Court dismissed the mandamus petition and directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner unless such filings are signed by a member in good standing of The Florida Bar, holding that Petitioner's petition was frivolous and that Petitioner demonstrated a pattern of vexatious filing of meritless pro se requests for relief. View "Foley v. State" on Justia Law

The Supreme Court affirmed the sentence of death imposed at Defendant's second resentencing for first-degree murder, holding that the two issues raised by Defendant on appeal were foreclosed by this Court's jurisprudence.Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court subsequently granted Defendant two new penalty-phase proceedings, including the one at issue. In the instant penalty-phase proceeding, Defendant waived a penalty-phase jury, the presentation of mitigating evidence, and his presence. The trial court ultimately imposed a sentence of death. The Supreme Court affirmed, holding (1) Defendant's sentence did not violate the Eighth Amendment; and (2) Defendant's remaining arguments lacked merit. View "Orme v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's sixth successive motion for post-conviction relief under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in summarily denying the motion.Appellant was convicted of first-degree felony murder and armed robbery and was sentenced to death. Decades later, Appellant filed the sixth successive post-conviction motion at issue on appeal, arguing that two pieces of allegedly newly discovered evidence required extending the rationale in Roper v. Simmons, 543 U.S. 551 (2005), for barring the execution of defendants under the age of eighteen at the time of the offense to bar the execution of defendants under the age of twenty-one. The circuit court summarily denied relief. The Supreme Court affirmed, holding that the circuit court did not err in finding that Appellant's claim was untimely and that his request to extend Roper was meritless. View "Melton v. State" on Justia Law

The Supreme Court affirmed the orders of the circuit court summarily denying Appellant's second successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, denying his motion for a stay of execution, and sustaining objections to his public records requirements made under Fla. R. Crim. P. 3.852, holding that there was no error.After a retrial, a jury found Appellant guilty of first-degree murder, armed burglary, attempted sexual battery, and armed robbery and unanimously recommended a sentence of death. The trial court imposed the death sentence. On April 3, 2023 Governor Ron DeSantis signed Appellant's death warrant. Appellant filed a second successive motion for postconviction relief, alleging three claims. The circuit court summarily denied the motion. The Supreme Court affirmed the denial of Defendant's postconviction motion, as well as the circuit court's orders sustaining Appellant's objections to public records requests and denying a stay of execution, holding that Appellant was not entitled to relief. View "Barwick v. State" on Justia Law

The Supreme Court denied a pro se petition for writ of mandamus brought by Petitioner, a pretrial detainee in the custody of the Volusia County Jail, and sanctioned Petitioner as pro se barred.Petitioner engaged in what the Court described as "a vexatious pattern of filing meritless pro se requests for relief in the Court pertaining to several civil and criminal cases filed by or against him." The Supreme Court denied relief in each of his filing, including the current petition. The Supreme Court denied the petition and held that Petitioner failed to show cause why he should not be sanctioned for his abusive conduct. The Court thus directed the Clerk of Court to reject and future pleadings or other requests for relief submitted by Petitioner unless such filings were signed by a member in good standing of The Florida Bar. View "Sanders v. State" on Justia Law

The Supreme Court quashed the order of the trial court denying Petitioner's motion to disqualify the judge assigned to preside over his postconviction proceedings, holding that the trial court erred in denying the motion because Petitioner provided a legally sufficient basis for disqualification.Petitioner, an inmate convicted of first-degree murder and sentenced to death, filed a "Motion to Vacate Judgments of Conviction and Sentence With Special Request For Leave To Amend." Judge Elizabeth Scherer was assigned to preside over the postconviction proceedings. Petitioner filed a motion to disqualify Judge Scherer "due to the appearance of impropriety and actual bias," arguing that the circumstances of this case were of such a nature that they were sufficient to warrant an objectively reasonable fear on Petitioner's part that he would not receive a fair hearing before the judge. Judge Scherer denied the motion. The Supreme Court quashed the order below, holding that the combination of certain circumstances contained in the allegations in Petitioner's motion would create in a reasonably prudent person a well-founded fear of not receiving a fair and impartial proceeding. View "Tundidor v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death, holding that Defendant was not entitled to relief on any of his claims of error.Defendant pleaded guilty to first degree murder. After a penalty-phase trial, the court concluded that the aggravating circumstances far outweighed the mitigating circumstances, warranting a sentence of death. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in declining to grant Defendant's motion to continue; (2) the trial court did not err in rejecting two statutory mitigating circumstances; (3) Defendant failed to establish a constitutional defect with Florida's death-penalty statute; (4) Defendant's guilty plea was knowingly, intelligently, and voluntarily given; and (5) Defendant's remaining arguments were without merit. View "Wells v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree murder and his sentence imposed for a Class B1 felony, holding that Defendant was not entitled to relief on his allegations of error.In 2012, the legislature amended North Carolina's murder statute to classify second-degree murders according to varying degrees of severity based on the level of culpability with which the criminal defendant acted. Under the amended statute, most kinds of second-degree murder are classified at the Class B1 felony level, but when it is determined that an offender acted with depraved-heart malice, second-degree murder is classified as a Class B2 felony. In 2019, Defendant was convicted of second-degree murder. At issue was whether Defendant should have been sentenced at the lower B2 felony level, instead of at the class B1 felony level, because the jury concluded that he acted with depraved-heart malice. The Supreme Court affirmed Defendant's sentence, holding that, under the circumstances, the trial court properly sentenced Defendant at the class B1 level because the jury's completed verdict form was not ambiguous. View "Furst v. Rebholz" on Justia Law

The Supreme Court found that Petitioner, who filed a pro se petition for a writ of habeas corpus, failed to show cause why he should not be barred and sanctioned him as set forth in this opinion.Petitioner was convicted of one count of armed robbery with a non-deadly weapon and sentenced to life imprisonment. Including this Petitioner, Petitioner had filed fourteen pro se petitions with the Supreme Court, including the habeas corpus petition at issue. The Supreme Court denied the petition, concluding that the petition was a frivolous proceeding, and directed the clerk of court to reject any future pleadings or other requests for relief submitted by Petitioner, holding that if no action is taken, Petitioner will continue to burden the Supreme Court's resources. View "Green v. Dixon" on Justia Law