Justia Florida Supreme Court Opinion Summaries

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

After a nonjury trial, Appellant was convicted of first-degree murder, armed robbery, burglary of a dwelling, and grand theft of an automobile. Appellant was sentenced to death for the murder conviction. The Supreme Court affirmed. Thereafter, Appellant filed a motion to vacate his conviction of first-degree murder and sentence of death, presenting twenty-one claims for relief. The postconviction court denied all of Appellant’s claims. Appellant appealed the denial of his postconviction motion and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the postconviction court’s denial of relief and denied habeas relief, holding (1) penalty phase counsel did not provide ineffective assistance; (2) Appellant was not deprived of his right to self-representation; (3) Appellant’s claims that his waivers of guilt phase counsel and both guilt and penalty phase juries were not knowing, intelligent, and voluntary were procedurally barred; and (4) as to Appellant’s habeas claims, his arguments regarding the effective assistance of appellate counsel were without merit. View "Knight v. State" on Justia Law

Defendant pleaded guilty to two counts of armed sexual battery, armed burglary, and armed robbery. Defendant was fifteen years old at the time he committed the offenses. The trial court sentenced Defendant to two life sentences and two concurrent twenty-five-year terms. After Graham v. Florida was decided, the trial court resentenced Defendant to concurrent sentences of forty-five years. On appeal, the First District Court of Appeal concluded that Defendant was not entitled to resentencing under Henry v. State, which applied the new sentence review statute to a Graham-eligible defendant, because Defendant’s forty-five-year term of imprisonment did not constitute a de facto life sentence in violation of Graham. However, the district court certified a question to the Supreme Court regarding the need for clarity on a category of Graham cases. The Supreme Court disapproved the court of appeal’s decision affirming Defendant’s resentencing, holding that a defendant whose initial sentence for a nonhomicide crime violated Graham and who was resentenced to concurrent forty-five year terms was entitled to new resentencing under the framework established in chapter 2014-220, Laws of Florida. View "Kelsey v. State" on Justia Law

Petitioner was convicted of two counts of first-degree murder. A jury recommended sentences of death. The Supreme Court affirmed the convictions and one of the death sentences but vacated the other death sentence with instructions to enter a life sentence. In a later evidentiary hearing, experts testified that Petitioner met the criteria for intellectual disability. The circuit court denied relief, concluding that Petitioner did not meet the statutory definition of intellectual disability. The Supreme Court affirmed. Petitioner then filed this petition for writ of habeas corpus asserting that the Court should revisit its prior decision that Petitioner was not intellectually disabled based on the new standard imposed by Hall v. Florida. The Supreme Court granted the petition and remanded the case for an evidentiary hearing, holding that Petitioner was entitled to an evidentiary hearing to establish whether he has an intellectual disability. View "Cherry v. Jones" on Justia Law

In 1981, Appellant was convicted of three counts of first-degree murder, among other crimes. Appellant was sentenced to death. The Supreme Court affirmed on direct appeal. The Supreme Court later granted Appellant’s petition for a writ of habeas corpus. Following a mistrial, Appellant was retried and again convicted and sentenced to death. The Supreme Court affirmed. The Supreme Court later granted Appellant’s third successive postconviction motion and vacated his sentences of death. Following a new penalty phase proceeding in 2013, the jury recommended that Appellant be sentenced to death for each of the three murders. The Surpeme Court vacated Appellant’s death sentences and remanded the case to the circuit court for a new penalty phase proceeding, holding that Appellant’s death sentences violate Ring v. Arizona and Hurst v. Florida because the jury that recommended Appellant’s death sentences did not find the facts necessary to sentence him to death. View "Johnson v. State" on Justia Law

Defendant was convicted of two counts of attempted murder of a law enforcement officer with possession and discharge of a firearm during commission of that crime and two counts of attempted armed robbery with possession of a firearm during commission of that crime. The trial court vacated its initial sentencing order and resentenced Defendant to two terms of thirty years for the attempted murders with mandatory minimum sentences of twenty years and two terms of fifteen years for the attempted armed robberies with mandatory minimum sentences of ten years. The court ordered that all sentences and mandatory minimums run consecutively. The First District Court of Appeal reversed Defendant’s sentences because he was not present at resentencing but otherwise found the sentences proper. The Supreme Court quashed the First District’s decision and remanded for a new trial, holding (1) the First District erred in concluding that section 775.087 required Defendant’s sentences to be imposed consecutively, irrespective of whether Defendant fired, carried, or displayed a firearm; (2) the trial court committed fundamental error by failing to instruct the jury on attempted manslaughter as a lesser included offense of second-degree murder; and (3) the suggestive identification procedure employed in this case gave rise to a substantial likelihood of irreparable misidentification. View "Walton v. State" on Justia Law