Justia Florida Supreme Court Opinion Summaries

The Supreme Court quashed in part the decision of the Fifth District Court of Appeal and remanded this case for resentencing proceedings, holding that the trial court committed harmful Alleyne error. See Alleyne v. United States, 470 U.S. 99, 114 (2013).During Defendant's criminal trial, the trial court made an Alleyne error and then purported to review its own decision to determine whether the Alleyne error was harmful. The Fifth District found harmful error, concluding that the only available remedy was to remand the case with instructions to resentence Defendant under a statutory provision that carried a lesser penalty. The Supreme Court upheld the Fifth District's ruling that the trial court committed harmful Alleyne error but quashed the decision to the extent it directed that only resentencing would be an appropriate remedy, holding that on remand after making an Alleyne error, a trial court is not foreclosed from empaneling a jury to make a factual determination that affects the legally-prescribed range of allowable sentences. View "State v. Manago" on Justia Law

In this case arising from two unrelated episodes in which a Tallahassee police officer used lethal force in detaining a suspect after asserting self-defense the Supreme Court held that Marsy's Law, Fla. Const. art. I, 16(b)-(e), guarantees to no victim, including a police officer, the categorical right to withhold his or her name from disclosure to the public.After the City of Tallahassee proposed to release the law enforcement officers' names to the public, the Florida Police Benevolent Association sought an emergency injunction to prevent that from happening. The trial court denied the injunction and ordered that the names of the two officers be released. The First District Court of Appeal reversed, concluding that nothing in article I, section 16 excluded police officers or other government employees from the protections granted crime victims. The Supreme Court quashed the decision of the First District, holding that Marsy's Law did not preclude the City from releasing the two police officers' names under the circumstances of this case. View "City of Tallahassee v. Fla. Police Benevolent Ass'n" on Justia Law

The Supreme Court affirmed Defendant's convictions of first-degree murder, attempted first-degree murder, aggravated assault with a deadly weapon, carjacking with a firearm, and possession of a firearm by a convicted felon and Defendant's death sentence, holding that there was no error.On appeal, Defendant raised thirteen challenges to his convictions and death sentence. The Supreme Court rejected all of Defendant's allegations of error, holding that none of Defendant's arguments on appeal were convincing and that there was sufficient evidence to support the convictions. View "Loyd v. State" on Justia Law

The Supreme Court affirmed the order of the trial court summarily denying Appellant's successive motion for DNA testing filed under Fla. R. Crim. P. 3.853, holding that that the trial court did not err in summarily denying Appellant's successive motion for DNA testing.Appellant was found guilty to two counts of first-degree murder and one count of second-degree murder and sentenced to death for each first-degree murder conviction. This case arose after Appellant filed a second motion requesting DNA testing. The trial court summarily denied the successive motion as procedurally barred and insufficiently pled. The Supreme Court affirmed, holding (1) Appellant's request for DNA testing was procedurally barred; and (2) even if Appellant's claim were not procedurally barred his motion still would not support relief. View "Reynolds v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition for writ of habeas corpus challenging his conviction and pro se barred Petitioner, an inmate in state custody, holding that Petitioner failed to show cause why he should not be barred and sanctioned.Petitioner was convicted of attempted second-degree murder and possession of a firearm by a convicted felon. Including the habeas corpus petition in the instant case, Petitioner filed thirty-one pro se petitions with the Supreme Court, and the Court never granted Petitioner the relief he sought in his filings. The Supreme Court held that Petitioner had abused this Court's limited judicial resources, concluded that Petitioner's habeas petition was a frivolous proceeding, and directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner unless such filings are signed by a member of The Florida Bar. View "Chestnut v. Dixon" on Justia Law

The Supreme Court pro se barred Petitioner, an inmate in state custody, holding that Petitioner failed to show cause why he should not be barred and sanctioned.Petitioner was convicted of lewd and lascivious sexual battery of a victim twelve to fifteen years old lewd and lascivious exhibition using a computer and traveling to meet a minor for sex. Including the habeas corpus petition in the instant case, Petitioner filed nineteen pro se petitions with the Supreme Court, but the Court never granted Petitioner the relief he sought in his filings. As to the current action seeking a writ of habeas corpus, the Supreme Court held that Petitioner had abused this Court's limited judicial resources, concluded that Petitioner's habeas petition was a frivolous proceeding, and directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner unless such filings are signed by a member of The Florida Bar. View "Levin v. State" on Justia Law

The Supreme Court affirmed the judgment of the postconviction court summarily denying the claims in Michael Duane Zack, III's fourth successive postconviction motion and denied Zack's motion for stay of execution and request for oral argument, holding that Zack was not entitled to relief.Defendant was sentenced to death for the murder of Ravonne Smith and was scheduled for execution on October 3, 2023. In his successive postconviction motion Defendant claimed that his execution should be barred under the Eighth Amendment. The postconviction court summarily denied the claims as untimely, procedurally barred, and meritless. The Supreme Court affirmed and denied Zack's motion for stay of execution and request for oral argument, holding that the postconviction court did not err by summarily denying Defendant's claims as untimely, procedurally barred, and meritless. View "Zack v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's second successive motion for postconviction relief, which was filed under Fla. R. Crim. P. 3.851, holding that the postconviction court did not err in denying Appellant's motion as untimely.Appellant was convicted of first-degree murder and sentenced to death. Appellant later filed his second successive motion for postconviction relief, claiming that newly discovered evidence rendered his death sentence unreliable. The postconviction court summarily denied the motion as untimely. The Supreme Court affirmed, holding that Appellant failed to establish the timeliness of his successive postconviction petition. View "Damren v. State" on Justia Law

The Supreme Court denied Respondent's petition for a writ of mandamus and sanctioned Respondent, an inmate in state custody, by directing the clerk of court to reject any future pleadings or requests for relief submitted by Respondent related to his second-degree murder conviction unless such filings are signed by a member of The Florida Bar, holding that Respondent's petition was frivolous.Respondent was convicted of second-degree murder and sentenced as a habitual violent felony offender to life imprisonment. After the court of appeal affirmed, Respondent began demonstrating "a pattern of vexatious filing of meritless pro se requests for relief," including the instant mandamus petition. The Supreme Court denied the petition and directed Respondent to show cause why he should not be barred from filing any further pro se requests for relief. The Supreme Court then sanctioned Respondent, holding that Respondent had abused the Court's limited judicial resources. View "Calvin v. State" on Justia Law

The Supreme Court approved the decision of the Third District Court of Appeal concluding that Florida's extortion law, Fla. Stat. 836.05, requires the State to prove that the defendant made a threat "intentionally and without a lawful justification," holding that the lower court properly interpreted the statute.At issue was whether the State must prove that Defendant, who threatened to ruin the reputation of two fellow real estate brokers unless they paid him, made this threat with hatred for the complainants under section 836.05. While the Third District answered in the negative, the Fifth District Court of Appeal concluded that "maliciously" in section 836.05 required proof that Defendant acted with ill will or hatred. The Supreme Court approved the Third District's decision and disapproved the Fifth District's decision, holding that the trial court and court of appeal each decided correctly that the term "maliciously," as used in the statute, means "intentionally and without any lawful justification." View "Tomlinson v. State" on Justia Law