Justia Florida Supreme Court Opinion Summaries

Petitioner pleaded guilty to armed burglary of a dwelling, armed kidnapping, attempted first-degree murder, and sexual battery using force or a weapon. Petitioner was sentenced to six concurrent life sentences. Petitioner’s sentences were based on offenses he committed when he was seventeen years old. After the United States Supreme Court issued its decision in Graham v. Florida, the trial court set aside Petitioner’s life sentences and, after an evidentiary hearing, resentenced Petitioner to 100 years in prison for the first count and forty years on each remaining count, to run concurrently. The Fifth District Court of Appeal affirmed Petitioner’s sentence, concluding that Graham does not apply to term-of-years sentences. The Supreme Court quashed the decision of the Fifth District, holding that Petitioner’s 100-year sentence violates Graham and the Supreme Court’s decisions in Henry v. State and Kelsey v. State. Remanded. View "Johnson v. State" on Justia Law

Prior to trial, Petitioner filed a motion in limine seeking to exclude witness testimony about the identity of the substances found at the scene of his arrest and the results from the chemical field tests performed on those substances, arguing that the witnesses were not qualified to testify as expert witnesses. The trial court denied the motion, concluding that the officer who performed the chemical field tests and identified the methaphetamine was sufficiently qualified to testify as an expert witness. Petitioner then entered an open plea of no contest to charges of conspiracy to manufacture methamphetamine, manufacture of methamphetamine, and possession of a listed chemical, reserving his right to appeal the ruling on the motion in limine, which the State agreed was dispositive of the case. Petitioner appealed, arguing that the challenged evidence failed to comply with the standard for admissibility in Daubert. The Fifth District Court of Appeal dismissed Petitioner’s appeal for lack of jurisdiction, concluding that the trial court’s order was not dispositive and therefore could not be challenged on direct appeal. The Supreme Court quashed the Fifth District’s decision, holding that, in appeals from conditional no contest pleas, stipulations of dispositiveness are binding on the appellate court. Remanded. View "Churchill v. State" on Justia Law

Petitioner pled nolo contendere to three counts of sexual battery of child under the age of twelve by a person under the age of eighteen and one count of lewd or lascivious molestation. The trial court imposed costs for each of the four convictions, resulting in costs of $603 pursuant to Fla. Stat. 938.08, $453 pursuant to Fla. Stat. 938.085, and $404 pursuant to Fla. Stat. 938.10(1). Petitioner appealed, arguing that the trial court erred in assessing the costs per count, instead of per case. The Fifth District Court of Appeal affirmed. The Supreme Court approved the decision of the Fifth District, holding that sections 938.085, 938.08, or 938.(1) require an imposition of costs per count. View "McNeil v. State" on Justia Law

After a jury trial, Appellant was found guilty of premeditated first-degree murder and of attempted second-degree murder. The trial court, following the jury’s recommendation, sentenced Appellant to death. The Supreme Court affirmed Appellant’s conviction and death sentence on direct appeal. Appellant then filed a motion for postconviction relief under Fla. R. Crim. P. 3.851, raising multiple claims of ineffective assistance of counsel during the guilt phase and claiming that he was entitled to relief after the United States Supreme Court issued its decision in Hurst v. Florida. The trial court denied the motion. The Supreme Court affirmed the denial of the guilt phase claims but vacated the death sentence and remanded for a new penalty phase pursuant to Hurst v. State, holding that where the jury recommended death by a vote of ten to ten, the error in Appellant’s sentencing was not harmless beyond a reasonable doubt. View "McMillian v. State" on Justia Law

The State charged Defendant with attempted first-degree premeditated murder. The State did not charge or allege the elements of attempted felony murder in the charging document. During trial, the State pursued an attempted felony murder theory. Defendant objected to the State’s proffered jury instruction on attempted felony murder, but the trial court overruled the objection. During closing argument, the State argued both the attempted premeditated murder theory and attempted felony murder. The jury returned a verdict of guilty on the attempted first-degree murder counts. The Court of Appeal affirmed. The Supreme Court quashed the decision below, holding (1) because the statutory crime of attempted felony murder is a crime separate from attempted premeditated murder, the State must charge the crime of attempted felony murder in order to be entitled to a jury instruction on that crime and proceed under that theory; and (2) the State’s failure to properly charge Defendant with the crimes that it was pursuing was unconstitutional and a violation of Defendant’s right to notice of the charges against him. View "Weatherspoon v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder. The jury recommended the death penalty for each murder by a vote of seven to five. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s convictions and sentences of death. Defendant then filed a timely motion for postconviction relief, raising six claims. The circuit court denied the motion for postconviction relief after an evidentiary hearing. The Supreme Court affirmed the denial of relief as to Defendant’s ineffective assistance of guilt phase counsel claim but vacated Defendant’s sentences of death, holding that the Hurst error in Defendant’s case was not harmless beyond a reasonable doubt. Remanded for a new penalty phase proceeding. View "Robards v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree premeditated and felony murder and armed robbery. The jury recommended the death penalty by a vote of eight to four. The trial court sentenced Defendant to death in accordance with the jury’s recommendation. The Supreme Court affirmed Defendant’s convictions but vacated the death sentence, holding (1) the evidence was sufficient to support Defendant’s conviction for first-degree premeditated and felony murder; and (2) Defendant’s death sentence violates Hurst v. State, and the Hurst error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Newberry v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder. The jury recommended death 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 conviction and sentence. Defendant later filed a motion for postconviction relief. The circuit court denied relief on all claims following an evidentiary hearing. Defendant appealed the denial of postconviction relief and also petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of postconviction relief but vacated the death sentence, holding (1) the circuit court correctly denied relief on Defendant’s ineffective assistance of counsel claims; (2) appellate counsel did not provide ineffective assistance; and (3) 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 "Abdool v. State" on Justia Law

Defendant was convicted of three counts of murder. The trial court followed the jury’s recommendation of death for the murder of a five-year-old girl but sentenced Defendant to life imprisonment for the other two murders. The Supreme Court affirmed. Defendant then filed a motion for postconviction relief. The trial court denied the motion after holding an evidentiary hearing. The Supreme Court affirmed the convictions but vacated the death sentence, holding (1) the trial court properly denied Defendant’s claims that trial counsel provided ineffective assistance; and (2) because the jury recommended the death penalty by a vote of ten to two, 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 "Heyne v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended a sentence of death by a vote of seven to five. The trial court followed the jury’s recommendation and imposed a sentence of death. The Supreme Court affirmed Defendant’s conviction but reversed his death sentence, holding (1) the trial court did not err in denying Defendant’s motions for mistrial during the guilt phase; (2) any error by the State in its statements during closing arguments did not rise to the level of fundamental error; (3) the evidence was sufficient to sustain a felony-murder conviction; but (4) the failure to require a unanimous verdict was not harmless in this case. Remanded to the trial court for a new penalty phase. View "Guzman v. State" on Justia Law