Justia Florida Supreme Court Opinion Summaries

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

Petitioner pleaded guilty to one count of traveling to meet a minor under Fla. Stat. 847.0135(4)(b). Petitioner was sentenced to six days time served and five years of sex offender probation. One condition of Petitioner’s sex offender probation required Petitioner to successfully complete a sex offender treatment program. Petitioner was later discharged from the sex offender treatment program for refusing to admit to any sexual misconduct necessitating treatment and, as a result, was charged with violating the conditions of his probation. After a hearing, the trial court revoked Petitioner’s probation, finding that the State presented sufficient evidence of a violation. The Fifth District Court of Appeal affirmed. The Supreme Court approved the Fifth District’s decision, holding that a refusal to admit sexual misconduct can constitute a violation of probation. View "Staples 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, contending that his rifle was a permissible antique firearm or “replica” thereof under Fla. Stat. 790.23. Section 790.23 prohibits convicted felons from possessing “any firearm.” In the alternative, Defendant argued that the felon-in-possession statute was unconstitutionally vague if it prohibited convicted felons from possessing black-powder rifles. The trial court denied Defendant’s motion to dismiss and adjudicated him guilty of the offense. The First District Court of Appeal reversed Defendant’s conviction, holding that section 270.23 was unconstitutionally vague. 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 (1) a “replica” of an “antique firearm” under the statutory definition is construed as emphasizing the type of firing system of the replica antique firearm as its distinctive feature; and (2) therefore, Defendant was entitled to the statutory exception of the felon-in-possession statute because his firearm was a permissible “replica” of an “antique firearm.” View "State v. Weeks" on Justia Law

Defendant pleaded guilty to twenty counts of transmitting child pornography to an undercover officer via the Internet. Defendant appealed, arguing that the use of a file-sharing program for the dissemination of child pornography does not violate the statutory prohibition on transmitting child program. The trial court denied relief, and the Fourth District Court of Appeal affirmed. The Supreme Court approved the decision of the Fourth District, holding that the use of a file-sharing program, where the originator affirmatively grants the receiver access to child pornography placed by the originator in files accessible through a file-sharing program, constitutes the transmission of child pornography under Fla. Stat. 847.0137. View "Smith v. State" on Justia Law

Petitioner was convicted of a felony and sentenced to two years in the Department of Corrections. As part of a work release program, Petitioner began employment with a construction company, working outside of the correctional facility during the daytime. On July 29, 2014, Petitioner reported to his employer and then left his place of employment without permission. Petitioner was unaccounted for until he timely returned to the work release center. Petitioner was subsequently charged with escape. The trial court granted Petitioner’s motion to dismiss, but the Fifth District Court of Appeal reversed, concluding that deviation from a work release program establishes a prima facie case for escape. The Supreme Court approved the decision below, holding that, pursuant to the applicable statutes, an inmate is confined when he is working as part of a work release program, and if an inmate leaves without permission he or she is subject to a charge of escape. View "Poillot v. State" on Justia Law

Appellant was convicted of murder and sentenced to death. After the Supreme Court decided in Atkins v. Virginia that the Eighth Amendment prohibits the execution of a person with an intellectual disability, Appellant filed a successive motion to vacate his sentence. The circuit court denied Appellant’s claim. The Fifth Circuit affirmed, concluding that the Supreme Court’s interpretation, in Cherry v. State, of Fla. Stat. 921.137(1) was proper. The Supreme Court affirmed, holding that the circuit court properly denied Appellant’s claim where Appellant failed to establish that his IQ was below 70. The United States Supreme Court reversed, holding that Florida courts may not have a bright-line cutoff IQ test score where it bars the consideration of other evidence of deficits in intellectual and adaptive functioning. On remand, the Supreme Court vacated Appellant’s death sentence and remanded with instructions to enter a life sentence, holding that Appellant presented sufficient evidence that he met the clinical and statutory definition of intellectual disability. View "Hall v. State" on Justia Law