Justia Florida Supreme Court Opinion Summaries

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

Defendant was charged with one count of possession of a firearm by a convicted felon. Defendant moved to dismiss the charge, arguing (1) his rifle was a permissible antique firearm or replica thereof under Fla. Stat. 790.23, the felon-in-possession statute, and (2) section 790.23 is unconstitutionally vague if convicted felons are prohibited from possessing black-powder rifles. The trial court denied the motion to dismiss, and Defendant entered a plea of no contest to one count of constructive possession of a firearm by a convicted felon. The First District Court of Appeal reversed, holding that section 790.23 is unconstitutional with respect to the possession of a replica of an antique firearm by a convicted felon. The Supreme Court approved the First District’s reversal of Defendant’s conviction but not its conclusion that section 790.23 is unconstitutionally vague, holding that Defendant was entitled to the statutory exception of the felon-in-possession statute because his firearm was a permissible “replica” of an “antique firearm” under section 790.23, as defined in Fla. Stat. 790.001(1). View "State v. Weeks" on Justia Law

Jacob John Dougan was convicted of a murder that occurred in 1974. Dougan was sentenced to death for the murder. Dougan filed an amended postconviction petition raising twenty-nine claims. The postconviction proceedings lasted more than twenty years. After an evidentiary hearing in 2013, the postconviction court granted relief as to multiple claims and vacated the murder conviction and sentence of death. Specifically, the postconviction court found (1) the State failed to disclose the full extent of its plea deal with William Hearn, the State’s only eyewitness to the murder, and allowed Hearn to testify falsely about the true nature of his deal with the State; and (2) Dougan’s guilt phase counsel was operating under two conflicts of interest and that ineffective assistance of counsel occurred in the guilt phase. The Supreme Court affirmed, holding that Dougan’s trial was tainted by the cumulative effect of the State’s violation of Giglio v. United States through the testimony of Hearn and the substandard performance of Dougan’s counsel, thus depriving Dougan of a fair and impartial trial. View "State v. Dougan" on Justia Law

After a jury trial, Clemente Javier Aguirre-Jarquin (“Aguirre”) was convicted of first-degree murder and sentenced to death. Aguirre later filed a postconviction motion under Fla. R. Crim. P. 3851, arguing that counsel was ineffective for failing to investigate alternate suspects, including Samantha Williams, who admitted to killing her family. The trial court denied relief. While Aguirre’s appeal was pending in the Supreme Court, Aguirre filed a successive postconviction motion arguing that he was entitled to a new trial based upon newly discovered evidence regarding Williams that came to light during the initial postconviction hearing and that was developed after the close of evidence in that proceeding. The circuit court denied the successive motion, concluding that Aguirre’s successive postconviction motion constituted an abuse of process and that, on the merits, Williams’ statements were inadmissible hearsay and, alternatively, that the statements made by Williams were not likely to produce an acquittal. Aguirre appealed the denial of his initial and successive postconviction motions and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court reversed the circuit court and vacated Aguirre’s convictions and sentences, holding that the cumulative effect of the newly discovered evidence required a new trial. Remanded for a new trial. View "Aguirre-Jarquin v. State" on Justia Law

This case involved a pending prosecution where the death penalty was sought. At issue was whether Florida’s newly enacted death penalty law (the Act), which was passed after the United States Supreme Court in Hurst v. Florida held that a portion of Florida’s capital sentencing scheme was unconstitutional, may be constitutionally applied to pending prosecutions for capital offenses that occurred prior to the new law’s effective date. In State v. Perry, the Fifth District Court of Appeal held that the Act could apply to pending prosecutions without offending the Constitution. The Fifth District then certified two questions of law to the Supreme Court. The Supreme Court answered, holding (1) as decided on remand in Hurst v. State, Hurst v. Florida did not declare Florida’s death penalty unconstitutional, and because Fla. Stat. 775.082(2) is limited to those cases in which the defendant was “previously sentenced to death,” the statute is inapplicable; and (2) the Act cannot constitutionally be applied to pending prosecutions because it does not require unanimity in the jury’s final recommendation as to whether the defendant should be sentenced to death, contrary to the Supreme Court’s holding in Hurst v. State. View "Perry v. State" on Justia Law

In Hurst v. State, the Supreme Court affirmed Defendant’s death sentence, which was imposed after a second penalty phase sentencing proceeding. Defendant sought certiorari review. Upon review, the United States Supreme Court reversed, holding that Florida’s capital sentencing scheme was unconstitutional to the extent that the judge, independent of a jury’s fact-finding, finds the facts necessary for imposition of the death penalty. The Court left it to the Florida Supreme Court to consider whether the error in sentencing was harmless beyond a reasonable doubt. On remand, the Supreme Court held (1) the United States Supreme Court's decision in Hurst v. Florida requires that a jury must unanimously find the critical findings necessary before the trial court may consider imposing a death sentence, and in order for the trial court to impose a sentence of death, the jury’s recommended sentence of death must be unanimous; (2) Fla. Stat. 775.082(2) does not mandate that Defendant receive an automatic life sentence; but (3) the error in Defendant’s sentencing was not harmless beyond a reasonable doubt. Remanded for a new penalty phase proceeding. View "Hurst v. State" on Justia Law