Justia Florida Supreme Court Opinion Summaries

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

Here the Supreme Court considered two petitions for writs of prohibition filed in Evans v. State and Rosario v. State. In Evans, the trial court determined that it would death qualify the jury in Evans’ first-degree murder trial and instruct the jury that Evans could receive a death sentence if the jury unanimously made the requisite findings of fact and unanimously recommended a death sentence. In Rosario, the trial court determined that the State was prohibited from seeking the death penalty in a pending prosecution and ordered that the case proceed with a mandatory life maximum penalty. The Fifth District Court of Appeal granted the State’s petition for a writ of prohibition. The Supreme Court denied Evans’ and Rosario’s petitions for writs of prohibition, holding that the trial courts in both cases may proceed with death qualifying juries, as, pursuant to the Court’s holdings in Hurst v. State and Perry v. State, the revised statutory scheme in chapter 2016-13, Laws of Florida, can be applied to pending prosecutions for a jury recommendation of death if twelve jurors unanimously determine that a defendant should be sentenced to death. View "Evans v. State" on Justia Law

Defendant pled no contest to multiple offenses arising out of a road rage incident. The trial court adjudicated Defendant guilty and imposed a downward sentence. At the sentencing hearing, the prosecutor argued against a downward sentence. The First District affirmed the trial court’s decision to impose a downward departure sentence, concluding that the State failed to preserve the issue for appeal. The Supreme Court quashed the First District’s decision, holding that because the State timely opposed the downward departure during the same proceeding in which the sentence was imposed, the issue was properly preserved for appellate review as to the legal grounds asserted. View "State v. Wiley" on Justia Law

Defendant was convicted and sentenced to death for the first-degree premeditated murder of a corrections officer. The Supreme Court affirmed Defendant’s convictions and sentence. Defendant later filed a motion to vacate his judgment of conviction and sentence pursuant to Fla. R. Crim. P. 3.851, alleging ineffective assistance of counsel and that his execution will violate his constitutional rights. The postconviction court denied relief. Defendant appealed and also filed a petition for writ of habeas corpus, claiming that the jury instructions in capital sentencing are unconstitutional and that trial counsel was ineffective in litigating constitutional challenges to Florida’s capital sentencing statute. The Supreme Court affirmed the postconviction court’s denial of Defendant’s postconviction motion, holding (1) Defendant failed to demonstrate that the postconviction court erred in finding that no Strickland error occurred; (2) Defendant’s claim of possible incompetence at the time of execution was not ripe for review; and (3) Defendant failed to establish that he was entitled to habeas relief. View "Hall v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended death by a vote of ten-to-two. The trial court sentenced Defendant to death. The Supreme Court affirmed on direct appeal. Defendant later filed an amended motion to vacate his conviction and sentence under Fla. R. Crim. P. 3.851. The trial court denied the motion. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of postconviction relief and denied the habeas petition, holding (1) the postconviction court properly denied relief on Defendant’s Rule 3.851 motion; and (2) Defendant was not entitled to habeas relief. View "Bogle v. State" on Justia Law

After a second jury trial, Defendant was found guilty of both first-degree premeditated murder and felony murder, with burglary as the underlying felony. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s convictions but vacated his death sentence, holding (1) the trial court did not err in denying Defendant’s motion for mistrial based on juror misconduct; (2) the evidence presented by the State was sufficient to support the first-degree premeditated murder conviction and the first-degree felony murder conviction; (3) the trial court did not commit reversible error by allowing the instruction on felony murder based on burglary to go to the jury; (4) the trial court did not err in denying Defendant’s motion for change of venue; and (5) Hurst error occurred because the recommendation of death in this case was not unanimous, and the error was not harmless. Remanded for a new penalty phase proceeding. View "Dubose v. State" on Justia Law