Justia Florida Supreme Court Opinion Summaries

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

Petitioner was convicted of two counts of lewd or lascivious molestation for touching the victim’s breasts and touching the victim’s buttocks. The court of appeal affirmed, concluding (1) the trial court did not err in restricting cross-examination of the victim and her mother, and (2) Petitioner’s convictions did not violate double jeopardy. The Supreme Court affirmed Petitioner’s convictions and sentences, holding (1) Petitioner’s dual convictions under the lewd or lascivious molestation statute did not violate double jeopardy; and (2) the trial court did not err in restricting defense counsel’s cross-examination of the victim and her mother. View "Graham v. State" on Justia Law

Defendant argued that the trial court erred as a matter of law by sentencing him for attempted second-degree murder (count III) to 40 years with a 25-year mandatory minimum pursuant to Fla. Stat. 775.087(2), the 10-20-Life statute. In this case, the trial court imposed a total sentence of 40 years’ imprisonment for count III, with a 25-year mandatory minimum sentence. The trial court did not impose its entire sentence pursuant to the 10-20-Life statute. The court concluded that a sentence imposed pursuant to the 10-20-Life statute is a mandatory minimum sentence that is not eligible for gain-time or early release. Therefore, the court quashed the First District’s decision in Hatten v. State and remanded for resentencing. The court also approved the holding of the Fourth District in Wiley v. State certified to be in conflict by the First District in Hatten, as well as the holdings certified to be in conflict from the Second, Fourth, and Fifth Districts. View "Hatten v. Florida" on Justia Law

Defendant was convicted of multiple crimes stemming from the alleged arsons of his truck and residence. The First and Fourth District Courts of Appeal reached conflicting decisions regarding the due process implications of admitting the testimony of State experts who physically examined the vehicle prior to its destruction where the defendant’s expert did not have that opportunity. The court applied the well-established rule from Arizona v. Youngblood and held that the State’s loss or destruction of evidence potentially useful to the defense violates due process only when done in bad faith. Therefore, the court held that no due process violation occurred in defendant's case because there is no evidence of bad faith. The court approved the result of the First District’s decision in Patterson v. State and disapproved the Fourth District’s pre-Youngblood decision in Lancaster v. State. View "Patterson v. Florida" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death. On appeal, defendant challenged an order denying his motion to vacate a judgment of conviction of first-degree murder and a sentence of death under Florida Rule of Criminal Procedure 3.851. The court affirmed the circuit court's denial of defendant's motion for postconviction relief, finding that a witness for the prosecution did not recant his trial testimony and that further impeachment of the witness with his inconsistent statement would not have produced an acquittal or lesser sentence at retrial. View "Mansfield v. Florida" on Justia Law

Petitioner was driving a truck with when the passenger opened the passenger door. The passenger suddenly left the moving vehicle and was later found dead on the ground adjacent to the roadway. Petitioner was convicted of leaving the scene of a crash that resulted in death in violation of Florida’s hit-and-run statute. The First District Court of Appeal affirmed, concluding that a driver’s vehicle may be “involved in a crash” pursuant to the statute when a passenger separates from a moving vehicle and lands on the roadway or adjacent area. The Supreme Court quashed the decision below, holding (1) the statutory phrase “any vehicle involved in a crash” means that a vehicle must collide with another vehicle, person, or object; and (2) under the facts of this case, no vehicle was involved in a collision within the meaning of the statute, and therefore, Petitioner’s conviction cannot be upheld. View "Gaulden v. State" on Justia Law