Justia Florida Supreme Court Opinion Summaries

Petitioner is incarcerated in the Florida Department of Corrections upon his judgments of conviction and sentences for robbery with a firearm, aggravated battery with firearm, and other offenses. In 2005, Petitioner began filing petitions in the Supreme Court challenging his incarceration. Since that time, Petitioner has filed eleven additional extraordinary writ petitions or notices. The Supreme Court has never granted Petitioner the relief sought in any of his filings. The instant petition, in which Petitioner sought habeas corpus relief, Petitioner attempted to collaterally attack the legality of his convictions and sentences based on a claim that the trial court lacked jurisdiction due to fundamental errors. The Supreme Court held that Petitioner’s writ of habeas corpus is a frivolous proceeding brought before the Court by a state prisoner and directed the Clerk of Court to reject any future pleadings or filings submitted by Petitioner unless such filings are signed by a member in good standing of the Florida Bar. View "Grimsley v. Jones" on Justia Law

After a jury trial, Defendant was convicted of the first-degree murder of a corrections officer at the Columbia Correctional Institution. The jury ultimately recommended a sentence of death, and the trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s conviction but vacated his death sentence, holding (1) the record sufficiently supports Defendant’s conviction of first-degree murder; but (2) Florida’s capital sentencing scheme is unconstitutional in light of the United States Supreme Court’s decisions in Ring v. Arizona and Hurst v. Florida because the jury that recommended death did not find the facts necessary to sentence Defendant to death, and the error was not harmless. Remanded for a new penalty phase proceeding. View "Franklin v. State" on Justia Law

After a jury trial, Appellant was found guilty of two counts of first-degree murder, two counts of kidnapping, two counts of robbery, and one count of carjacking. The trial court sentenced Defendant to death for each murder and to life imprisonment for each of his other convictions. The Supreme Court affirmed the convictions and sentences. This appeal concerned Appellant’s renewed motion for determination of intellectual disability and his amended motion to vacate judgment and sentences. The postconviction court ultimately denied both motions. The Supreme Court affirmed, holding (1) in regards to Appellant’s amended motion to vacate judgment and sentences, the postconviction court did not err in denying Appellant’s claims of ineffective assistance of counsel or his claim that the cumulative effect of those errors deprived him of a fair trial; and (2) in regards to Appellant’s renewed motion for intellectual disability, the postconviction court did not err in finding that Appellant is not intellectually disabled. View "Wright v. State" on Justia Law

In 2012, Defendant was charged in an information with several counts related to child pornography. After Defendant was arrested on an arrest warrant issued in 2009 for possession of child pornography, he filed a motion to dismiss claiming that the applicable statute of limitations barred his prosecution. The State countered that Defendant was outside the state from 2008 until 2012 and, thus, the statute of limitations had not run because it was tolled the entire time pursuant to Fla. Stat. 775.15(5). The trial court denied Defendant’s motion to dismiss, concluding that section 775.15 tolls the statute of limitations when the defendant is continuously absent from the state. Defendant then entered a plea of no contest to the charges and was adjudicated guilty on all counts. The First District Court of Appeal affirmed. The Supreme Court approved the decision and disapproved the decisions of the Second District Court of Appeal in Netherly v. State and State v. Perez to the extent they hold that, under section 775.15, the State must prove that the State conducted a diligent search for the defendant while he was continuously absent from the state or that the defendant’s absence from the state hindered the prosecution in order to toll the statute of limitations. View "Robinson v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder and one count each of armed robbery, attempted robbery, and conspiracy to commit armed robbery. The trial court imposed two sentences of death for the murder convictions. The Supreme Court affirmed Defendant’s judgments of conviction but remanded the case to the trial court with instructions that the court impose life sentences for each of Defendant’s convictions for first-degree murder, holding (1) competent, substantial evidence supported the convictions; and (2) because the murders in this case were not among the most aggravated and least mitigated, the death penalty is a disproportionate punishment. View "Phillips v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder. The jury recommended death sentences for the murder convictions, and the trial court sentenced Defendant to death. The Supreme Court affirmed the convictions but vacated Defendant’s death sentences, holding (1) the trial court did not err by denying Defendant’s motion to suppress his confession and the corresponding video recording of it; (2) the trial court did not abuse its discretion by precluding a false confession expert from testifying that Defendant’s statement to law enforcement was coerced; (3) the trial court did not err by advising the jury that the ultimate decision to impose the death penalty rested with the court; (4) the evidence was sufficient to support the first-degree murder convictions; but (5) the term-of-years sentences imposed against Defendant’s codefendants precluded Defendant’s death sentences. View "McCloud v. State" on Justia Law

Appellant was convicted of first-degree murder and sentenced to death. After the United States Supreme Court ruled in Atkins v. Virginia that it was unconstitutional to execute persons with intellectual disabilities, Appellant raised claims that he was intellectually disabled and could not be executed. The trial court and Supreme Court denied relief, relying, in part, on the bright-line cutoff of an IQ score of 70 that was subsequently invalidated in theUnited States Supreme Court’s holding in Hall v. Florida. This appeal concerned Appellant’s seventh motion for postconviction relief, alleging that his death sentence violated the Eighth and Fourteenth Amendments under Atkins. The postconviction court summarily denied Appellant’s motion. The Supreme Court reversed, holding that failing to give Appellant the benefit of Hall would result in a manifest injustice, which is an exception to the law of the case doctrine. Remanded for a new evidentiary hearing regarding intellectual disability, to be conducted pursuant to Hall. View "Thompson v. State" on Justia Law

Appellant was the Appellant in two separate death penalty direct appeals. In the present case, Appellant was convicted of two counts of first-degree murder, one count of attempted first-degree murder, and one count each of attempted armed robbery and possession of a firearm by a convicted felon. Appellant was sentenced to death for both of the murders. The Supreme Court affirmed the trial court’s judgments of conviction and sentences of death, holding (1) the trial court did not commit prejudicial error in its rulings; (2) the evidence was sufficient to support Appellant’s attempted robbery conviction; (3) Appellant’s death sentences were proportionate; and (4) the Florida death penalty statutory scheme is facially constitutional under Ring v. Arizona. View "Davis v. State" on Justia Law

After a jury trial, Appellant was convicted of three counts of first-degree murder, one count of attempted first-degree murder, one count of armed robbery, and one count of first-degree arson. The trial court imposed two sentences of death. Defendant appealed his convictions and sentences. The Supreme Court affirmed the trial court’s judgments of conviction and sentences of death, holding (1) the trial court properly admitted the statements of one victim as a dying declaration; (2) the trial court did not err in admitted certain out-of-court and in-court identifications of Appellant; (3) the trial court did not err in admitting nearly four dozen autopsy and hospital photographs of the murder victims; (4) the trial court properly found that Appellant committed the murder of one victim in order to avoid arrest; (5) competent, substantial evidence of guilt supported Appellant’s convictions; and (6) Appellant’s death sentences satisfied the Court’s proportionality requirement. View "Davis v. State" on Justia Law

Appellant was convicted of felony murder in the death of Edward Alger and premeditated and felony murder in the death of Ann Peterson. The trial judge sentenced Appellant to death for Peterson’s murder and to life imprisonment for Alger’s murder. In 2006, Appellant filed his first successive postconviction motion, alleging that his death sentence was improper because he was intellectually disabled. The circuit court denied relief after an evidentiary hearing. In 2015, Appellant filed his second successive postconviction motion, arguing that his death sentence was unconstitutional because the United States Supreme Court’s decision in Hall v. Florida changed the definition of subaverage intellectual function to include IQ scores that are 75 or below, and because the previous intellectual disability hearing was directed at satisfying the constitutional definition of an IQ that is 70 or below, he was entitled to a new hearing. The circuit court summarily denied Appellant’s successive motion without granting a hearing. The Supreme Court reversed, holding (1) Hall applies retroactively; and (2) Appellant was entitled to a new evidentiary hearing as to his claim of intellectual disability. View "Walls v. State" on Justia Law