Justia Florida Supreme Court Opinion Summaries

The Supreme Court granted Petitioner’s petition for a writ of habeas corpus, vacated his death sentence, and remanded for a new penalty phase, holding that Petitioner’s death sentence violated Hurst v. State, 202 So. 3d 40 (2016) because the jury verdict at the penalty phase was not unanimous. Petitioner was convicted of two counts of first-degree murder. The jury recommended a sentence of death by a vote of ten to two. After determining that Petitioner fell within the category of defendants to whom Hurst is applicable, the Supreme Court held that the error that occurred during the penalty phase was not harmless beyond a reasonable doubt. View "Hertz v. Jones" on Justia Law

The Supreme Court affirmed the circuit court’s order summarily denying Appellant’s successive motion for postconviction DNA testing pursuant to Fla. R. Crim. P. 3.853. In the instant postconviction motion, Appellant, a prisoner under sentence of death, sought DNA testing of ten items, seven of which were previously requested in his first Rule 3.853 motion. The Supreme Court held (1) Appellant’s claims as to the aforementioned seven items were procedurally barred; and (2) the circuit court did not err in denying DNA testing on the three remaining items because there was no reasonable probability that the results of DNA testing on these three additional items would have resulted in Appellant’s acquittal or reduced his sentence. View "Bates v. State" on Justia Law

Petitioner was convicted of lewd and lascivious battery, three counts of lewd and lascivious molestation, and lewd and lascivious conduct. Petitioner was sentenced to life in prison on each count, to run concurrently. Petitioner was sentenced to a mandatory minimum of twenty-five years after the trial court declared him to be a dangerous sexual felony offender (DSFO). Petitioner later filed a motion pursuant to Fla. R. Crim. P. 3.800(a), contending that the predicate conviction the trial court used to qualify him as a DSFO was insufficient. The Fourth District Court of Appeal affirmed the sentence. The Supreme Court approved the decision below, holding (1) under the Dangerous Sexual Felony Offender Act, a conviction for an offense under Fla. Stat. 800.04 constitutes a “similar offense under a former destination” to those offenses enumerated in the Act; and (2) therefore, the Fourth District did not err in affirming Petitioner’s designation as a DSFO offender. View "Acevedo v. State" on Justia Law

The Supreme Court vacated Matthew Lee Caylor’s death sentence and remanded the case for a new penalty phase, holding that Caylor’s death sentence was unconstitutional under Hurst v. Florida, 136 S. Ct. 616 (2016) because the jury verdict at the sentencing phase was not unanimous, and the error in Caylor’s penalty phase was not harmless beyond a reasonable doubt. The court thus granted Caylor’s petition for a writ of habeas corpus but affirmed the trial court’s denial of postconviction relief, holding that the trial court did not err in summarily denying that counsel was ineffective for failing to challenge a purportedly biased juror. View "Caylor v. State" on Justia Law

On direct appeal, the Supreme Court reversed Appellant’s convictions for two counts of first-degree murder and vacated his two death sentences, holding that the evidence presented at trial was insufficient to sustain the convictions. The evidence of guilt presented at trial was wholly circumstantial. The court held that although the facts established at trial supported a “strong suspicion of guilt,” they were not inconsistent with innocence and that the evidence did not establish “a reasonable and moral certainty that the accused and no one else committed the offense[s] charged.” Lindsey v. State, 14 So. 3d 215 (Fla. 2009)(quoting Frank v. State, 163 So. 223 (Fla. 1935)). View "Wright v. State" on Justia Law

Petitioner pleaded guilty to murder in the first degree and robbery with a weapon. The jury returned a unanimous recommendation that Petitioner be sentenced to death. The trial court found five aggravating factors and nineteen nonstatutory mitigating circumstances and sentenced Petitioner to death. In this petition seeking a writ of habeas corpus, Petitioner argued 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 denied relief, holding that the Hurst violation was harmless beyond a reasonable doubt. View "Guardado v. Jones" on Justia Law

The Florida Supreme Court vacated Nelson Serrano’s four death sentences imposed after he was convicted for four counts of first-degree murder and remanded for a new penalty phase pursuant to Hurst v. State, 202 So. 3d 40. Serrano had appealed the denial of his postconviction motion filed under Fla. R. Crim. P. 3.851 and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the postconviction court’s denial of Serrano’s guilt phase claims and denied his habeas petition. However, the court held that Serrano was entitled to relief under Hurst because the jury recommended death on all four murder counts by a vote of nine to three, and the error in Serrano’s sentencing was not harmless beyond a reasonable doubt. View "Serrano v. State" on Justia Law

On direct appeal, the Florida Supreme Court vacated Barry Trynell Davis, Jr.’s two death sentences and remanded for a new penalty phase pursuant to Hurst v. State, 202 So. 3d 40. Davis was convicted of two counts of first-degree murder. After a penalty phase, a nonunanimous jury recommended two sentences of death. The Supreme Court held (1) the Hurst error in this case was not harmless; (2) the trial court did not err in denying Davis’s motion to suppress; (3) the trial court did not err in admitting evidence of Davis’s prior possession of a revolver; (4) the trial court did not err in allowing the State to display, during closing argument, a photo of a witness crying on the witness stand; and (5) the evidence was sufficient to support the convictions. View "Davis v. State" on Justia Law

The Florida Supreme Court vacated David Beasher Snelgrove’s two death sentences and ordered that Snelgrove receive a new penalty phase proceeding based on the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. (2016) and this court’s decision in Hurst v. State, 202 So. 3d 40 (Fla. 2016). After a second penalty phase, the trial court followed the jury’s nonunanimous recommendation of death sentences for Defendant’s two murder convictions. Here, Snelgrove appealed the denial of his petition for postconviction relief pursuant to Fla. R. Crim. P. 3.851 and also petitioned the Florida Supreme Court for a writ of habeas corpus. The court affirmed the denial of Snelgrove’s rule 3.851 motion and denied the petition for writ of habeas corpus but vacated his death sentences, holding that Hurst was applicable in this case and that the failure to require a unanimous jury recommendation was not harmless beyond a reasonable doubt. The court remanded the cause for a new penalty phase. View "Snelgrove v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree premeditated or felony murder with a weapon and his sentence of death, holding (1) the trial court did not err in denying Defendant’s challenges for cause against two prospective jurors; (2) the trial court did not abuse its discretion in admitting the rebuttal testimony of the State’s mental health expert; (3) any error in the trial court's finding of the avoid arrest aggravator was harmless; (4) the State’s penalty phase evidence did not become an impermissible feature of the penalty phase; (5) the Hurst v. State error in this case was harmless beyond a reasonable doubt; (6) the evidence was sufficient to support Defendant’s conviction; and (7) the death sentence in this case was proportionate. View "Cozzie v. State" on Justia Law