Justia Florida Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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On direct appeal, the Supreme Court affirmed Defendant’s convictions of two counts of first-degree murder but vacated his two sentences of death. The death sentences were imposed after a nonunanimous jury recommended sentences of death. The failure to require a unanimous verdict as to each death sentence was not harmless, thus entitling Defendant to a new penalty phase based on Hurst v. State. As to Defendant’s guilt phase claims, the court held that no prejudicial error occurred. In addition, the court held that the evidence presented by the State was sufficient to sustain Defendant’s first-degree murder convictions. The court remanded the case for a new penalty phase. View "Pasha v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court held that Petitioner, whose sentence of death was recommended by his penalty phase jury after a vote of eleven to one, was entitled to relief under Hurst v. State and Hurst v. Florida. The Court granted Petitioner’s petition for habeas corpus, vacated his death sentence, and remanded the matter to the circuit court for a new penalty phase, determining (1) Hurst applied retroactively to Petitioner, whose sentence became final four days after the United States Supreme Court issued its opinion in Ring v. Arizona; and (2) the Hurst error in Petitioner’s penalty phase proceeding was not harmless beyond a reasonable doubt. View "Card v. Jones" on Justia Law

Posted in: Criminal Law
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The Supreme Court granted John Lee Hampton’s petition for a writ of habeas corpus, vacated Hampton’s sentence of death, and ordered that Hampton receive a new penalty phase proceeding in light of Hurst v. State. In addition, the Court affirmed the postconviction court’s order denying Hampton’s motion to vacate his conviction of first-degree murder and sentence of death to the extent it denied Hampton relief based upon his claim of ineffective assistance of guilt phase counsel and further affirmed the determination that Hampton was not intellectually disabled. The Court declined to address the remaining issues in Hampton’s appeal of the postconviction court’s order, which relate to penalty phase issues, due to its holding that the Hurst error during Hampton’s penalty phase proceedings was not harmless beyond a reasonable doubt. View "Hampton v. State" on Justia Law

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Defendant was convicted of two counts of attempted second-degree murder. The First District Court of Appeal reversed the convictions because the trial court “failed to instruct that [Defendant] could not be guilty of attempted manslaughter if the attempted killings were either justifiable or excusable homicide.” The court then certified the same question of great public importance that it previously certified in Moore v. State. The Supreme Court approved the holding of the First District and answered the certified question as follows: where the record reflects there was no evidence presented from which a jury could find justifiable or excusable attempted homicide, fundamental error occurs when the trial court fails to instruct on justifiable or excusable attempted homicide, and the defendant is convicted of attempted manslaughter or a greater offense not more than one step removed. View "State v. Spencer" on Justia Law

Posted in: Criminal Law
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Defendant was convicted of first-degree murder. The jury recommended the death penalty by a vote of nine to three. The Supreme Court followed the recommendation and sentenced Defendant to death. Defendant filed a motion to vacate his conviction and sentence under Fla. R. Crim. P. 3.851. The circuit court denied the motion. Defendant appealed this denial and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court vacated the death sentence and remanded for a new penalty phase, holding (1) the trial court did not err in denying Defendant’s ineffective assistance of trial counsel and appellate counsel claims; and (2) Defendant’s death sentence violated Hurst v. State, and the Hurst error was not harmless beyond a reasonable doubt. View "Altersberger v. State" on Justia Law

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Appellant was convicted of first-degree murder, two counts of attempted felony murder, and two counts of attempted first-degree murder. Appellant was sentenced to death for the murder conviction. The Supreme Court vacated Appellant’s attempted felony murder convictions and affirmed Appellant’s conviction for first-degree murder and sentence of death, holding (1) Appellant’s convictions for two counts of attempted first-degree murder and two counts of attempted felony murder violated double jeopardy principles, but resentencing for the capital or noncapital convictions is not necessary; and (2) the remainder of Appellant’s claims did not entitle him to relief. View "Tundidor v. State" on Justia Law

Posted in: Criminal Law
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Appellant was convicted and sentenced to death on two counts for the first-degree premeditated murders of two police officers. The Supreme Court affirmed the convictions and sentences, holding (1) the trial court did not err in denying Appellant’s motion to strike the jury panel based on statements made by a prospective juror during jury selection; (2) the trial court did not err in admitting a redacted statement statement while he was under observation in jail, and any error in preventing the defense from presenting evidence regarding Appellant’s mental state at the time he made the statement was harmless; (3) the trial court did not err in allowing law enforcement officers to give opinions identifying Appellant’s voice and image from a dash cam videotape; (4) the trial court did not err in admitting a witness’s prior consistent statements; (5) the trial court did not err in denying Appellant’s motion for mistrial; and (6) competent, substantial evidence supported Appellant’s convictions. View "Morris v. State" on Justia Law

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Appellant was convicted of first-degree murder, armed robbery, and other offenses. The jury recommended by a vote of twelve to zero that Appellant be sentenced to death for the murder. The trial court followed the jury’s recommendation and sentenced Appellant to death. The Supreme Court affirmed his death sentence on direct appeal. Appellant later filed a motion for postconviction relief. After an evidentiary hearing on two ineffective assistance of trial counsel claims related to Appellant’s alleged intellectual disability, the circuit court denied postconviction relief. The court also denied Appellant’s first and second successive postconviction motions. The Supreme Court affirmed, holding (1) the circuit court did not err in refusing to grant an evidentiary hearing on Appellant’s intellectual disability claim; and (2) Appellant was not entitled to relief under Hurst v. State. View "Rodriguez v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Donald Lenneth Banks was found guilty of first-degree murder. The jury recommended the death penalty by a vote of ten to two. Following the jury’s recommendation, the trial court sentenced Banks to death. On appeal, the Supreme Court affirmed Banks’ conviction and sentence. Thereafter, Banks filed a motion under Fla. R. Crim. P. 3.851 to vacate his murder conviction and sentence of death, alleging ineffective assistance of counsel. The postconviction court denied the motion. Banks appealed the denial of his Rule 3.851 motion and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of Banks’ postconviction guilt phase claims, denied his habeas petition, but vacated his death sentence, holding (1) trial court provided effective assistance of counsel; but (2) Banks’ death sentence violated Hurst v. State, and the Hurst error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Banks v. State" on Justia Law

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After a jury trial, Defendant was found guilty of first-degree premeditated and felony murder. The jury recommended the death penalty by a vote of ten to two. The trial court followed the jury’s recommendation and sentenced Defendant to death. The Supreme Court affirmed the convictions but vacated the death sentence, holding (1) the trial court did not err by admitting, for purposes of impeachment, collateral crime evidence that Defendant signed a sworn statement in which he admitted to concealing a metal shank inside his pants while in jail awaiting trial for the victim’s murder; (2) the State did not improperly comment on Defendant’s right to silence; (3) the evidence was sufficient to support Defendant’s conviction; but (4) Defendant’s death sentence violated Hurst v. State, and the Hurst error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Brookins v. State" on Justia Law