Justia Florida Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of first-degree murder. The jury returned a recommendation in favor of death by a vote of eight to four. The trial court accepted the recommendation and sentenced Defendant to death. The Supreme Court affirmed the conviction and vacated the death sentence, holding (1) it cannot be concluded beyond a reasonable doubt that a Hurst v. Florida error did not contribute to Defendant’s sentence; and (2) the trial court properly denied Defendant’s motion for judgment of acquittal, and there was no error in the guilt phase of trial. Remanded for a new penalty phase. View "Deviney v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, kidnapping, and home invasion robbery. At the conclusion of the penalty phase, the jury recommended death by a vote of nine to three. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s convictions and sentences. Defendant then filed a postconviction motion pursuant to Fla. R. Crim. P. 3.851. The trial court denied all relief after an evidentiary hearing. Defendant appealed the denial of his postconviction motion and also filed a petition for a writ of habeas corpus. The Supreme Court reversed the trial court’s denial of Defendant’s claim related to the constitutionality of Florida’s death penalty scheme, vacated Defendant’s death sentence as unconstitutional under Hurst v. Florida, and denied habeas relief, holding (1) the Hurst error in Defendant’s penalty phase was harmless beyond a reasonable doubt, and Defendant was entitled to a new penalty phase; and (2) Defendant’s remaining claims were unavailing. View "Baker v. State" on Justia Law

Appellant was convicted of first-degree murder, sexual battery with a deadly weapon, and other offenses. The trial court sentenced Appellant to death for the murder conviction. The Supreme Court affirmed Appellant’s convictions but reversed his sentences, holding (1) no prejudicial error occurred during the guilt phase of Appellant’s trial; but (2) Appellant’s death sentence was not based upon factual findings by a jury of his peers, as required by the Sixth Amendment, but upon a nonunanimous jury recommendation, and the Hurst v. Florida errors that occurred during sentencing were not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Jackson v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder. The jury recommended the death sentence by a vote of ten to two. The Supreme Court affirmed the conviction and the death sentence. Thereafter, Appellant filed a motion for postconviction relief under Fla. R. Crim. P. 3.851, raising twelve claims. The trial court denied relief. The Supreme Court affirmed the postconviction court’s oder as to Appellant’s conviction but vacated the death sentence and remanded for a new penalty phase, holding (1) Appellant was not denied the effective assistance of counsel under Strickland v. Washington; but (2) in light of the nonunanimous jury recommendation to impose a death sentence, it cannot be said that the failure to require a unanimous verdict in this case was harmless. View "Hodges v. State" on Justia Law

Defendant was charged with violating Fla. Stat. 384.24(2), which was enacted to prevent the spread of sexually transmissible diseases. The charge arose from a homosexual relationship between Defendant and the victim. Defendant moved to dismiss the charge under Fla. R. Crim. P. 3.190(c)(4), arguing that the term “sexual intercourse” applies only to penile-vaginal intercourse. The trial court granted the motion to dismiss based on the decision of the Second District Court of Appeal in L.A.P. v. State, which held that the term “sexual intercourse” as used in the statute applies only to “the penetration of the female sex organ by the male sex organ.” The Third District Court of Appeal reversed, holding that the term “sexual intercourse” as used in section 384.24(2) encompasses conduct beyond penile-vaginal intercourse and includes oral and anal intercourse between two men. The Supreme Court approved of the Third District’s decision and disapproved the decision of the Second District in L.A.P., holding that the term “sexual intercourse” in section 384.24(2) encompasses conduct beyond penile-vaginal intercourse. View "Debaun v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder, two counts of kidnapping, two counts of robbery, and one count of carjacking. The trial court sentenced Defendant to death for each murder and life imprisonment for each of his other convictions. The Supreme Court affirmed Defendant’s convictions and sentences. Defendant later filed an amended motion to vacate his judgment and sentences and a renewed motion for determination of intellectual disability. The postconviction court denied both motions. The Supreme Court affirmed, holding (1) the postconviction court properly determined that Defendant is not among those intellectually disabled defendants that cannot be executed; (2) with regard to every claim raised in Defendant’s amended motion to vacate his judgment and sentences, Defendant failed to demonstrate that the postconviction court erred in finding no Strickland error occurred; and (3) Defendant was not entitled to relief pursuant to Hurst v. Florida. View "Wright v. State" on Justia Law

After a jury trial, Defendant was convicted of four counts of first-degree murder, four counts of conspiracy to commit murder, two counts of manslaughter, and other crimes. The jury recommended by a vote of ten to two that Defendant be sentenced to death for one murder and also recommended a death sentence for another murder by a vote of nine to three. The trial court followed the jury’s death-sentence recommendations. The Supreme Court affirmed Defendant’s first-degree murder convictions and sentences of death on direct appeal. Defendant later filed a motion to vacate his convictions and sentences pursuant to Fla. R. Crim. P. 3.851, setting forth eight claims. The trial court denied Defendant’s Rule 3.851 motion. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the trial court’s denial of postconviction relief as to all claims except Defendant’s claim relating to the constitutionality of his penalty phase, denied habeas relief, vacated Defendant’s death sentences, and remanded for a new penalty phase, holding that Defendant’s death sentence was unconstitutional under Hurst v. Florida. View "Smith v. State" on Justia Law

Cary Michael Lambrix was convicted and sentenced to death for the 1983 first-degree murder of two victims. The Supreme Court affirmed Lambrix’s murder convictions and death sentences on direct appeal. After the Governor signed a death warrant and the execution was set, Lambrix filed both a successive motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851 and a motion for postconviction DNA testing pursuant to Fla. R. Crim. P. 3.853. The postconviction court summarily denied both of Lambrix’s motions. Lambrix appealed those orders and filed a petition for writ of habeas corpus. After the U.S. Supreme Court issued its opinion in Hurst v. Florida, the Supreme Court permitted supplemental briefing and oral argument to consider the impact of Hurst in this case. The Supreme Court ultimately affirmed the postconviction court’s denial of relief and denied Lambrix’s separate petition for habeas corpus, holding (1) Lambrix was not entitled to a new penalty phase based on Hurst v. Florida or Hurst v. State; and (2) the other grounds that Lambrix raised were devoid of merit. View "Lambrix v. State" on Justia Law

After a jury trial, Appellant was found guilty of two counts of first-degree murder and related crimes. The jury recommended death on both counts of murder. The trial court followed the jury’s recommendation and imposed two death sentences. The Supreme Court affirmed Appellant’s convictions, vacated his death sentence, and remanded for a new penalty phase based on an error in jury selection. Upon resentencing, the jury again recommended death for both murders. The trial judge sentenced Defendant to death for each count of first-degree murder. The Supreme Court affirmed the sentences of death. Appellant later filed a motion to vacate convictions for first-degree murder and sentences of death under Fla. R. Crim. P. 3.851, alleging that both guilt and penalty phase counsel were ineffective under Strickland v. Washington. The postconviction court denied each of Appellant’s claims. The Supreme Court vacated Appellant’s sentences of death, holding (1) the postconviction court did not err in denying relief on Appellant’s ineffective assistance of guilty phase counsel claim; (2) the Court declines to address Appellant’s ineffective assistance of penalty phase counsel claim; and (3) any Hurst error in Appellant’s sentencing was not harmless beyond a reasonable doubt. View "Ault v. State" on Justia Law