Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of two counts of first-degree murder and armed burglary of a dwelling with discharge of a firearm causing death. The trial court sentenced Defendant to death on both counts of first-degree murder and to life without parole on the burglary charge. Defendant appealed, raising four issues. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in admitting testimony regarding a shotgun that was not used to commit the killings and allowing the shotgun to be admitted into evidence; (2) the trial court did not err in denying Defendant’s motion for mistrial where the prosecutor argued lack of remorse; (3) the trial court did not err in finding that the murder of one of the victims was committed in a cold, calculated, and premeditated manner; (4) any Hurst error in Defendant’s penalty phase was harmless beyond a reasonable doubt; (5) there was sufficient evidence to support a conviction for first-degree premeditated murder; and (6) Defendant’s death sentence was proportionate. View "Oliver v. State" on Justia Law

Defendant was convicted of manslaughter with a firearm and sentenced to thirty years in prison. At sentencing, the trial judge imposed a lump sum of “approximately $956” in fines and court costs. The written order showed that the total included a discretionary fine and surcharge, which were not individually pronounced at sentencing. Defendant appealed. The Fifth District Court of Appeal affirmed, holding (1) the trial court did not err by denying Defendant’s motion for mistrial, and (2) Defendant’s argument that the trial court erred by not individually pronouncing the discretionary fine and surcharge at sentencing was not preserved because it was only a procedural challenge. The Supreme Court quashed the Fifth District’s decision insofar as it conflicts with this decision, holding that trial courts must individually pronounce discretionary fees, costs, and fines during a sentencing hearing to comply with due process requirements. Remanded for resentencing. View "Osterhoudt v. State" on Justia Law

Defendant was convicted of first-degree murder. The jury recommended that Defendant be sentenced to death by a vote of eight to four. The trial court followed the recommendation and imposed a death sentence. The Supreme Court affirmed Defendant’s first-degree murder conviction but vacated his death sentence, holding (1) the State presented sufficient evidence to support the conviction; but (2) the Hurst v. State error in Defendant’s case was not harmless beyond a reasonable doubt, as it was not clear beyond a reasonable doubt that the jury’s failure to unanimously find all the facts necessary for imposition of the death penalty did not contribute to Defendant’s death sentence. Remanded for a new penalty phase. View "White v. State" on Justia Law

Defendant was convicted of attempted second-degree murder of a law enforcement officer and first-degree felony murder of another victim, which was based on the attempted second-degree murder conviction. Defendant received two life sentences. The Fifth District reversed, concluding (1) the jury instructions were erroneous because they did not require the jury to find that Defendant knew that the victim was a law enforcement officer, but (2) Fla. Stat. 782.065 is a reclassification statute that does not create a separate substantive offense, and therefore, Defendant’s conviction of first-degree felony murder was unnecessary. The Supreme Court quashed the Fifth District’s decision to the extent that it held that section 782.065 does not create a substantive offense, holding that the statute is a reclassification statute that creates a substantive offense, and therefore, the proper remedy for the erroneous jury instructions would have been to vacate both of Defendant’s convictions and remand for a new trial. Remanded with directions to order a new trial on the charges of attempted second-degree murder of a law enforcement officer and first-degree felony murder. View "Ramroop v. State" on Justia Law

Defendant was convicted of second-degree murder. Defendant’s jury was instructed on the lesser included offense of manslaughter by act with the same instruction that the Supreme Court found to be fundamentally erroneous in State v. Montgomery. Defendant appealed, arguing that he was entitled to relief in light of Montgomery. The Fourth District Court of Appeal affirmed, thus rejecting the fundamental error claim based on the fact that the trial court also instructed the jury on the lesser included offense of manslaughter by culpable negligence. After the Supreme Court’s decision in Haygood v. State was issued, the Court granted Defendant’s petition for review, summarily quashed the decision of the Fourth District in Dominique I, and remanded for reconsideration in light of the Court’s decision in Haygood. The Fourth District reversed on remand, concluding that fundamental error occurred in the giving of the jury instruction for manslaughter by act, requiring a new trial. The Supreme Court quashed the decision of the Fourth District, holding (1) the evidence in this case reasonably supported the lesser included offense of manslaughter by culpable negligence; and (2) therefore, under Haygood, the giving of the manslaughter by culpable negligence instruction cured the fundamental error in the giving of the erroneous manslaughter by act instruction. View "State v. Dominique" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, robbery, fleeing and eluding, and resisting arrest with violence. At the penalty phase of trial, the jury recommended death by a vote of ten to two. The trial court followed the recommendation and sentenced Defendant to death. The Supreme Court affirmed the trial court’s denial of Defendant’s guilt phase claims but reversed and remanded for a new penalty phase, holding that because the non unanimous jury did not make the findings required under Hurst v. State, the error was not harmless, and Defendant was entitled to a new penalty phase under Hurst v. Florida, as interpreted by the Supreme Court in Hurst v. State. View "Bradley v. State" on Justia Law

After a jury trial, Defendant was convicted of premeditated or felony murder, robbery, and sexual battery. The jury recommended the death penalty by a vote of seven to five. The trial judge followed the recommendation and sentenced Defendant to death. Defendant appealed his death sentence. The Supreme Court affirmed. Defendant later filed the instant motion for postconviction relief, presenting, inter alia, ineffective assistance of counsel. The postconviction court denied all claims. Defendant appealed the denial of his motion, raising claims of ineffective assistance of resentencing phase counsel and ineffective assistance of postconviction counsel. Defendant also petitioned for a writ of habeas corpus, alleging ineffective assistance of appellate counsel. The Supreme Court vacated Defendant’s death sentence and remanded for a new penalty phase, holding that Defendant was entitled to a new penalty phase pursuant to Hurst v. Florida, as interpreted by the Court’s decision in Hurst v. State. View "Orme v. State" on Justia Law

In 2000, Petitioner was sentenced to life in prison for attempted first-degree murder and attempted robbery with a gun or deadly weapon. The Court of Appeal affirmed the convictions and sentences. Thereafter, Petitioner initiated a series of postconviction challenges to his convictions and sentences. The instant mandamus petition concerned the twelfth extraordinary writ petition Petitioner filed with the Supreme Court since 2010. The Supreme Court dismissed the petition and directed Petitioner to show cause why he should not be barred from filing any future pro se requests for relief. The Supreme Court then directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner that pertained to the criminal case at issue unless such filings were signed by a member in good standing of The Florida Bar. In addition, the Court found that the petition was a frivolous proceeding brought before the Supreme Court by a state prisoner. View "Pray v. Forman" on Justia Law

In 1987, Petitioner was convicted of several counts of uttering forgery. In 1992, Petitioner was convicted of robbery with a deadly weapon and robbery without a weapon. After his convictions and sentences became final, Petitioner repeatedly sought postconviction relief. Since 2000, Petitioner has filed, without success, twenty-six petitions or notices, the vast majority of which have concerned his 1987 forgery convictions and his 1992 robbery convictions and sentences. The instant habeas petition challenged, inter alia, Petitioner’s 1987 forgery convictions and his 1992 robbery convictions and sentences. The Supreme Court dismissed Petitioner’s habeas petition in part and dismissed it as unauthorized in part. The Court then directed Petitioner to show cause why he should not be barred from filing any further pro se requests for relief concerning his 1987 and 1992 convictions and sentences. The Supreme Court concluded that Petitioner’s response failed to show cause why he should not be sanctioned and concluded that the instant petition was a frivolous proceeding brought before the Court by a state prisoner. The Court then directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner that pertained to the convictions at issue unless such filings are signed by a member in good standing of The Florida Bar. View "Desue v. Jones" on Justia Law

In 1982, Petitioner pled guilty to several counts of attempted first-degree murder, robbery with a deadly weapon, and other offenses. Petitioner was sentenced to life imprisonment for those offenses. Thereafter, Petitioner repeatedly sought postconviction relief from his convictions and sentences. The instant habeas petition, in which Petitioner challenged his convictions and sentences along with the circuit court’s application of its barring order to a pro se postconviction motion that Petitioner attempted to file, was the twenty-fifth pro se petition or notice that Petitioner had filed with the Supreme Court since 2000. The Supreme Court dismissed the petition in part as meritless and dismissed it in part as unauthorized. In so doing, the Court expressly retained jurisdiction and directed Petitioner to show cause why he should not be barred from filing any future pro se requests for relief. The Court then concluded (1) Petitioner failed to show cause why sanctions should not be imposed, and (2) Petitioner’s petition in this case is a frivolous proceeding brought before the Supreme Court by a state prisoner. The Court then directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Defendant unless such filings were signed by a member in good standing of The Florida Bar. View "Roberts v. Jones" on Justia Law