Justia Florida Supreme Court Opinion Summaries

Defendant was convicted of first-degree murder, attempted first-degree murder, robbery with a firearm, and fleeing to elude a law enforcement officer. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s convictions and sentences. Defendant later filed an amended motion to vacate judgment of conviction and sentence under Fla. R. Crim. P. 3.851. After holding an evidentiary hearing, the postconviction court denied Defendant’s amended rule 3.851 motion, concluding that, due to Defendant’s failure to offer any evidence, the burden of proof had not been met. Defendant appealed the denial of postconviction relief and also filed a petition for writ of habeas corpus. The Supreme Court affirmed the denial of postconviction relief but granted the habeas petition and vacated Defendant’s death sentence, holding that a Hurst error occurred during Defendant’s penalty phase proceedings, and the error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase proceeding based on Hurst v. Florida. View "McGirth v. State" on Justia Law

Defendant was convicted of two counts of first-degree murder (premeditated and felony murder) in the death of Georgette Sturmfels, two counts of first-degree murder (premeditated and felony murder) for the death of Robert Sturmfels, and other offenses. The jury recommended two death sentences for both murders by a vote of eight to four. The trial court sentenced Defendant to death. The Supreme Court affirmed the premeditated murder convictions and death sentences, reversed the two felony murder convictions that were duplicative of the premeditated murder convictions, and remanded to the trial court. The lower court subsequently vacated one felony murder conviction for each victim. Defendant later filed his first successive motion to vacate the judgment of conviction challenging the premeditated murder convictions and death sentences, arguing an improper doubling of aggravators. The postconviction court summarily denied relief. The Supreme Court affirmed the denial of postconviction relief, holding that Defendant’s claim of improper doubling is untimely and procedurally barred. View "Gaskin v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury voted ten to two to impose the death sentence. The trial court sentenced Defendant to death. The Supreme Court affirmed. Defendant later filed a postconviction motion to vacate the judgment of conviction and sentence. The circuit court summarily denied Defendant’s postconviction motion. While Defendant’s appeal was pending, the United States Supreme Court issued its decision in Hurst v. Florida. The Supreme Court reversed the postconviction court’s order and remanded for a new penalty phase, holding that Defendant’s sentence was the result of a Hurst error, and the error was not harmless beyond a reasonable doubt. View "Kopsho v. State" on Justia Law

Defendant was convicted of one count of second-degree murder and two counts of attempted second-degree murder. Defendant appealed his second-degree murder conviction, arguing that he was entitled to relief because the jury instruction on the lesser included offense of manslaughter by act was erroneous. The district court concluded that the instruction did not constitute fundamental error. The Supreme Court reversed, holding (1) because manslaughter as a matter of degree is a next lesser offense of second-degree murder, giving an erroneous instruction on manslaughter by act constitutes fundamental error even if manslaughter is not listed immediately below second-degree murder on the verdict form; (2) in this case, the error caused by a faulty instruction on manslaughter by act was not cured by the jury’s consideration of other offenses that were also one step removed; and (3) because the jury convicted Defendant of attempted second-degree murder after being erroneously instructed on attempted voluntary manslaughter, Defendant is entitled to a new trial for the attempted homicides. Remanded with instructions that Defendant be granted a new trial. View "Daugherty v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, kidnapping, and robbery. The jury recommended that Defendant be sentenced to death for the murder by a vote of nine to three. After concluding that the aggravating factors outweighed the mitigating circumstances, the trial court imposed the death penalty. The Supreme Court affirmed Defendant’s convictions but reversed the death sentence in light of the U.S. Supreme Court’s decision in Hurst v. Florida and the Florida Supreme Court’s opinion on remand in Hurst v. State, holding that Defendant’s sentence was a result of a Hurst error, and the error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Williams v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, attempted murder, and armed robbery. Defendant was sentenced to death after the jury recommended a death sentence by a vote of nine to three. The Supreme Court, on appeal from the denial of postconviction relief, vacated Defendant’s death sentence and remanded for a new penalty phase. After the second penalty phase, the jury once again recommended the death sentence by a vote of nine to three. The Supreme Court affirmed. Defendant subsequently filed a motion to vacate his sentence of death under Fla. R. Crim. P. 3.851, raising ten claims. The circuit court denied relief. Defendant appealed and also petitioned for a writ of habeas corpus. The Supreme Court reversed the denial of postconviction relief, holding that Defendant’s sentence was a result of a Hurst v. Florida error, and the error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Armstrong v. State" on Justia Law

After a jury trial, Petitioner was convicted of second-degree murder. On appeal, Petitioner argued that the jury instruction on the required lesser included offense of manslaughter by act improperly required the jury to find that Petitioner intended to cause the victim’s death. Petitioner’s conviction was affirmed on the grounds that the jury also received an instruction on manslaughter by culpable negligence. The Supreme Court quashed the decision below and remanded in light of the Court’s decision in Haygood v. State. On remand, the district court again affirmed the conviction. The Supreme Court approved the ultimate holding of the district court but not the reasoning, holding (1) because the Fifth District employed the same reasoning as the Fourth District in Daughterty v. State, a decision the Supreme Court ultimately quashed, and applied an erroneous steps removed analysis, the Court disapproves of the reasoning in McCloud; but (2) the error caused by the incorrect instruction was cured by the jury’s consideration of other offenses also one step removed from the offense of conviction. View "McCloud v. State" on Justia Law

After a jury trial, Mark James Asay was found guilty of two counts of murder. The jury recommended a death sentence. The trial court imposed a sentence of death for each conviction. The Supreme Court affirmed on appealed. Here, Asay appealed from the summary denial of his second successive postconviction motion and also filed two petitions for a writ of habeas corpus. The Supreme Court affirmed the circuit court’s denial of postconviction relief and denied the petitions for a writ of habeas corpus, holding (1) Hurst v. Florida does not apply retroactively to Asay’s case, in which the death sentence became final before the issuance of Ring v. Arizona; and (2) Asay failed to demonstrate that he was entitled to relief as to any of his claims. View "Asay v. State" on Justia Law

Defendant was convicted of two counts of first-degree murder for the deaths of his girlfriend and their infant son. Defendant was sentenced to death for the murder of his son and to life imprisonment for the murder of his girlfriend. The Supreme Court affirmed. Defendant filed a petition for postconviction relief pursuant to Fla. R. Crim. P. 3.851, raising eighteen claims. The postconviction court denied relief. Defendant appealed and also petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the postconviction court’s denial of relief for a new trial but granted Defendant a new penalty phase based on the United States Supreme Court’s decision in Hurst v. Florida and the Supreme Court’s decision in Hurst v. State, holding (1) Hurst applies retroactively to Mosley; and (2) under the circumstances of this case, a Hurst error occurred during the penalty phase, and the State failed to show beyond a reasonable doubt that the Hurst error was harmless. View "Mosley v. State" on Justia Law

Defendant was convicted of the kidnapping, sexual battery, and death of Deborah Tressler. Defendant was sentenced to death after a unanimous jury recommendation in the first penalty phase. The Supreme Court ultimately vacated the sentence of death and remanded for a new sentencing proceeding because Defendant’s counsel failed fully to investigate and present mitigating evidence regarding Defendant’s mental health and childhood. After a new penalty phase, the jury returned a special interrogatory verdict indicating a unanimous finding that three aggravating factors were established beyond a reasonable doubt. The jury issued an advisory sentencing recommending death. The trial court entered a sentencing order imposing the death sentence after a Spencer hearing. Defendant appealed. Shortly before oral argument was held in this case, the United States Supreme Court decided Hurst v. Florida. The Florida Supreme Court vacated Defendant’s sentence of death and remanded the case to the trial court for a new penalty phase proceeding, holding (1) in accordance with Hurst, the jury did not unanimously conclude that the aggravating factors were sufficient or that the aggravating factors outweighed the mitigating circumstances; and (2) it cannot be said beyond a reasonable doubt that there was no possibility that the Hurst error contributed to the jury recommendation of death in this case. View "Simmons v. State" on Justia Law