Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first-degree premeditated murder and first-degree felony murder, among other crimes. The jury unanimously voted to impose the death penalty. The trial court followed the jury’s recommendation and sentenced Defendant to death. Defendant appealed his convictions and sentence of death. Here the Supreme Court granted Defendant’s motion for rehearing and substituted this revised opinion for its previous opinion issued October 22, 2015. The Court affirmed Defendant’s conviction of first-degree murder and upheld his death sentence, holding (1) the evidence was sufficient to sustain Defendant’s convictions; (2) any Hurst error was harmless beyond a reasonable doubt; and (3) no other prejudicial error occurred requiring reversal of Defendant’s convictions. View "Middleton v. State" on Justia Law

In 1999, Charles Anderson was convicted and sentenced to death for first-degree murder. The Supreme Court affirmed the conviction and sentence of death on direct appeal. Anderson filed an amended motion for postconviction relief seeking to vacate his conviction and death sentence under Fla. R. Crim. P. 3.851. The trial court denied three claims after an evidentiary hearing and summarily denied the remaining claims. Anderson appealed from the denial of his motion for postconviction relief and also petitioned the Supreme Court for a writ of habeas corpus. During the pendency of Anderson’s appeal, the United States Supreme Court issued its decision in Hurst v. Florida. The Supreme Court affirmed the postconviction court’s order as to Anderson’s conviction and denied Anderson’s habeas petition but vacated the death sentence, holding that, in light of the nonunanimous jury recommendation to impose a death sentence, it cannot be said that the failure to require a unanimous verdict here was harmless. Remanded for a new penalty phase. View "Anderson v. State" on Justia Law

Dale Lee Norman was charged with open carrying of a weapon in violation of Fla. Stat. 790.053, Florida’s Open Carry Law. Section 790.053 permits individuals to carry firearms in public so long as the firearm is carried in a concealed manner. After the jury found Norman guilty of the sole count of openly carrying a firearm in violation of Florida’s Open Carry Law, the county court certified three questions to the Fourth District Court of Appeal regarding the constitutionality of the law. The Fourth District upheld Florida’s Open Carry Law under intermediate scrutiny. The Supreme Court affirmed, holding (1) the State has an important interest in regulating firearms as a matter of public safety, and Florida’s Open Carry Law is substantially related to this interest; and (2) therefore, Florida’s Open Carry Law violates neither the Second Amendment to the U.S. Constitution nor article I, section 8 of the Florida Constitution. View "Norman v. State" on Justia Law

Petitioner was convicted of multiple counts of lewd or lascivious molestation against three victims over the course of differing time periods. The trial court sentenced Petitioner to life imprisonment for the counts involving a victim under the age of twelve years old and fifteen years’ imprisonment for each of the other counts. Defendant appealed, arguing that the trial court erred in failing to include his requested jury instructions for each count pertaining to the lesser included offense of unnatural and lascivious act. The Second District Court of Appeal affirmed, concluding that Petitioner failed to preserve his claim for appeal. The Supreme Court quashed the decision below, holding (1) Petitioner sufficiently preserved his request for a lesser-included offense instruction; and (2) Petitioner was entitled to the unnatural and lascivious act jury instructions he requested. View "Wong v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree premeditated murder. The jury unanimously recommended a sentence of death. The trial court followed the jury’s recommendation and sentenced Defendant to death. The Supreme Court affirmed, holding (1) the trial court did not err in admitting evidence of collateral crimes; (2) the trial court did not fundamental error by failing sua sponte to instruct the jury regarding the limited purpose of collateral crime evidence prior to its admission; (3) the trial court did not err in failing to appoint special counsel to present mitigation evidence during the penalty phase; (4) Defendant was not entitled to resentnecing on the grounds that a prior violent felony aggravating circumstance was premised on invalidated convictions because Defendant again stood trial and was convicted; (5) Defendant’s death sentence was constitutional, and any Hurst error was harmless beyond a reasonable doubt; (6) the evidence was sufficient to support the jury’s verdict; and (7) Defendant’s death sentence was proportional. View "Jones v. State" on Justia Law

Defendant was convicted of sexual battery on an inmate by a law enforcement officer and was sentenced to ten years of imprisonment and thirty years of community service. The court of appeal affirmed. Since 2012, Defendant has filed twelve previous extraordinary writ petitions pertaining to his conviction and sentence. All petitions have been frivolous, devoid of merit, or inappropriate for consideration by the Supreme Court. In the instant case, Defendant filed a habeas petition challenging his conviction and seeking immediate release and/or damages on several grounds. The Supreme Court found that the petition was a frivolous proceeding brought before the Supreme Court by a state prisoner and directed the clerk of court to reject any future pleadings or requests for relief submitted by Defendant pertaining to his criminal case unless such filings were signed by a member of the Florida Bar. View "Hawkins v. Jones" on Justia Law

After a jury trial, Defendant was found guilty of one count of robbery with a firearm. The jury also found that Defendant did “actually possess” a firearm during the robbery. The trial court sentenced Defendant to twenty-five years in prison and, based on the finding of actual possession, imposed a ten-year mandatory minimum sentence. The Fourth District Court of Appeal affirmed the conviction and sentence. Defendant later filed a motion to correct illegal sentence, arguing that his sentence was illegal because the allegation in the information that he carried a firearm was not sufficient to place him on notice that he was subject to an enhanced sentence. The circuit court denied the motion. The Fourth District affirmed, concluding that Defendant waived any challenge to the sufficiency of the information or the imposition of a mandatory minimum sentence. The Supreme Court approved the Fourth District’s decision, holding that the alleged defect in the charging document did not result in an illegal sentence subject to correction under Fla. R. Crim. P. 3.800(a). View "Martinez v. State" on Justia Law

Defendant was charged with the murder of her husband. Defendant filed a motion to suppress statements she made to police on two occasions at the police station after being interrogated by the police. The trial court granted the motion to suppress, finding that Defendant was in custody for the purpose of administering Miranda warnings based on the totality of the circumstances, and because she was not advised of her Miranda rights, the statements must be suppressed. The Fifth District Court of Appeal reversed, concluding that “a reasonable person in Defendant’s position would have felt free to terminate the interviews.” The Supreme Court quashed the Fifth District’s decision, holding that Defendant was in custody for purposes of Miranda warnings during both interrogations, and therefore, Defendant’s constitutional right against self incrimination was violated by the police’s failure to administer Miranda warnings before proceeding with the custodial interrogations. Remanded. View "Myers v. State" on Justia Law

Petitioner was involved in a single-vehicle car crash in which a single fatality occurred. After a jury trial, Petitioner was found guilty of DUI serious bodily injury and sentenced to five years of incarceration. Petitioner appealed, arguing that the trial court erred by admitting the results of a blood test because the law enforcement officer did not have probable cause to believe Petitioner was under the influence of alcoholic beverages before requiring him to submit to the blood draw taken after the traffic accident, as required by Fla. Stat. 316.1933(1)(a). The Third District Court of Appeal affirmed, ruling that the blood draw was constitutionally permissible under the fellow officer rule and, alternatively, that voluntary consent supported the blood draw. The Supreme Court quashed the decision of the Third District, holding (1) the fellow officer rule was inapplicable because there was no communication between the officers concerning Petitioner; and (2) Petitioner’s consent was involuntary because it was given in response to a threat to suspend his driver license for refusing to give consent by an officer lacking probable cause. View "Montes-Valeton v. State" on Justia Law

After a jury trial, Appellant was found guilty of the kidnapping and murder of Vincent Binder. The jury recommended that Appellant be sentenced to death by a unanimous vote. The trial court agreed with the jury’s unanimous vote and imposed a death sentence. The Supreme Court affirmed, holding (1) the trial court did not err in overruling the State’s use of a peremptory challenge to an African-American juror; (2) excluding people from the jury venire due to their age does not violate the Constitution; (3) the trial court did not err in permitting the State to introduce evidence of other crimes or acts for the purpose of proving a material fact in issue; (4) the cumulative effect of any improper closing comments made by the prosecutor did not entitle Appellant to a new trial; (5) the trial court’s rulings during the penalty phase did not deprive Appellant of a fair trial; (6) Appellant was not entitled to relief under Hurst v. Florida and Hurst v. State; and (7) the death penalty was not disproportionate. View "Truehill v. State" on Justia Law