Justia Florida Supreme Court Opinion Summaries

In 2004, when Petitioner was sixteen years old, she and her boyfriend committed murder. Petitioner was convicted of second-degree murder with a weapon, which was classified as a life felony. The trial court sentenced Petitioner to life without parole without indicating what findings of aggravating or mitigating circumstances warranted imposition of the life-without-parole sentence as opposed to a term-of-years sentence under the sentencing guidelines then in place. After the United States Supreme Court decided Miller v. Alabama, Petitioner filed a motion for postconviction relief in the form of resentencing. The circuit court denied the motion. The Second District Court of Appeal affirmed, concluding that because Petitioner was sentenced under a discretionary sentencing scheme, Miller was inapplicable to Petitioner’s life-without-parole sentence. The Supreme Court quashed the Second District’s decision, holding that Miller applies to juvenile offenders whose sentences of life imprisonment without parole were imposed pursuant to a discretionary sentencing scheme when the sentencing court, in exercising that discretion, did not take into account the individualized sentencing considerations of a juvenile offender’s youth. View "Landrum v. State" on Justia Law

Appellant, a death row prisoner, challenged the circuit court’s order denying his successive motion for postconviction relief filed under Florida Rules of Criminal Procedure 3.850 and 3.851. Appellant argued that his codefendant's statements that he saw a struggle between appellant and the victim before the victim was shot, and that he had a plea agreement in place at the time of trial, constitute newly discovered evidence warranting a new trial. Having considered appellant’s newly discovered evidence and the evidence that could be introduced at a new trial, including the evidence introduced in appellant’s prior postconviction proceedings, the court agreed with the circuit court’s conclusions that there is no probability of an acquittal on retrial. The court also concluded that appellant's argument regarding the cumulative effect of the new evidence on the outcome of the penalty phase is also without merit. The court affirmed the circuit court's denial of relief on appellant's claims under United States v. Giglio because appellant did not demonstrate that the codefendant's testimony was false and thus failed to establish the prosecutor's knowledge of any such false testimony, and Brady v. Maryland where his claim is not supported by competent, substantial evidence. Accordingly, the court affirmed the circuit court's order denying appellant's successive motion for postconviction relief. View "Melton v. Florida" on Justia Law

Petitioner, sixteen-years-old at the time he committed the offenses, was convicted of armed robbery and first-degree murder. Under the statute then in effect, petitioner was sentenced for the first-degree murder to a mandatory term of life imprisonment, with the possibility of parole after twenty-five years, and was sentenced to life imprisonment without the possibility of parole for the armed robbery. Under the existing statutory scheme, the Commission conducted a parole hearing and set petitioner's presumptive parole release date, which is the earliest date he may be released from prison as determined by objective parole guidelines, for the year 2130 - one hundred and forty years after the crime and far exceeding petitioner’s life expectancy. The court concluded that Florida’s existing parole system, as set forth by statute, does not provide for individualized consideration of petitioner’s juvenile status at the time of the murder, as required by Miller v. Alabama, and that his sentence, which is virtually indistinguishable from a sentence of life without parole, is therefore unconstitutional. Accordingly, the court quashed the Fourth District Court of Appeal's underlying decision upholding the sentence and remanded for resentencing. View "Atwell v. Florida" on Justia Law

Petitioner was incarcerated upon his judgments of conviction and sentences for trafficking in stolen property and uttering a forged instrument. Since 2001, Petitioner filed at least twenty-seven extraordinary writ petitions and eight notices seeking discretionary review. In the instant petition, Petitioner sought a writ of habeas corpus. The Supreme Court dismissed Petitioner’s petition and directed Petitioner to show cause why he should not be barred from filing in the Court any future pro se requests for relief and why he should not be sanctioned for the volume of his meritless and inappropriate filings. Petitioner filed a response to the Court’s order to show cause. The Court concluded that the response failed to show cause why sanctions should not be imposed. The Court then instructed the Clerk of Court to reject any future filings submitted by Petitioner related to his aforementioned criminal cases unless such filings were signed by a member in good standing of the Florida Bar. View "Smith v. Jones" on Justia Law

In 1992, Appellant was convicted of first-degree murder and six other offenses stemming from a robbery of a fast food restaurant. Appellant was sentenced to death for the murder. Appellant later filed a habeas petition, which the federal district court denied. On appeal, the Eleventh Circuit granted habeas relief, set aside Appellant's death sentence, and remanded the case for a new penalty phase. Prior to the commencement of Appellant's new penalty phase, Appellant filed a motion based on newly discovered evidence. The trial court dismissed the motion as premature, concluding that because Appellant was awaiting resentencing, his conviction was not final for purposes of filing a successive postconviction motion. The Supreme Court reversed, holding that motions for a new trial based on newly discovered evidence should not be delayed until after the death sentence is final but, instead, should be brought as soon as possible after the discovery of the new evidence. Remanded. View "Farina v. State" on Justia Law

Defendant was stopped by two police officers for a violation of Fla. Stat. 316.605(1), which requires a license plate to be plainly visible and free of “obscuring matter.” A seizure of evidence during the course of the traffic stop resulted in criminal charges against Defendant. Defendant filed a motion to suppress, arguing that the stop was invalid. The trial court granted the motion. The Fifth District Court of Appeal reversed, concluding that Defendant violated the statute when his tag light, along with its attached wires, was hanging down in front of his license plate. Defendant appealed, arguing that a hanging tag light did not constitute the type of obscuring matter contemplated by the statute because the tag light was external to the license plate, not on it. The Supreme Court approved the decision of the Fifth District, holding that section 316.605(1) requires that a license plate be plainly visible and legible at all times without regard to whether the obscuring matter is on or external to the plate. View "English v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder with a firearm. During the trial, the State presented evidence of Defendant’s pre-arrest, pre-Miranda silence and argued that the jury should consider this silence as evidence of Defendant’s consciousness of guilt. The Court of Appeal reversed and remanded for a new trial, concluding that because Defendant did not testify at trial, the use of her pre-arrest, pre-Miranda silence was precluded as a matter of state constitutional and evidentiary law. The Supreme Court approved of the Court of Appeal’s decision, holding (1) use of a defendant’s silence as substantive evidence of guilt violates the Florida constitutional right against self-incrimination; and (2) as a matter of Florida evidentiary law, the State is precluded from using that silence to argue a defendant’s consciousness of guilt. View "State v. Horwitz" on Justia Law

Appellant was convicted of one count of robbery with a firearm while wearing a mask. Appellant was twenty years old when he committed the crime but twenty-one years old when he was tried and sentenced. If Appellant had been sentenced under the youthful offender statute, he faced a six-year cap as to his sentence. Instead, Appellant was sentenced to the statutory maximum of life in prison. Appellant filed a motion to correct an illegal sentence. The motion was deemed denied. The Court of Appeal affirmed the sentence. Before the Supreme Court, Appellant raised a facial challenge to the constitutionality of Fla. Stat. 958.04(1)(b), arguing that the statute (1) violates equal protection because the age-at-sentencing classification creates arbitrary and irrational distinctions between otherwise eligible defendants, and (2) violates due process because, in attempting to be eligible for youthful offender sentencing, a defendant may forgo certain constitutional rights. The Supreme Court affirmed, holding (1) because section 958.04(1)(b), as amended, bears a rational relationship to a legitimate government objective, it does not violate equal protection; and (2) the statute does not violate due process because it serves a legitimate state interest. View "Jackson v. State" on Justia Law

Defendant entered an open plea to the charge of armed burglary of a dwelling. Before sentencing, the State filed a sentencing memorandum recommending that the court consider a new charge pending against Defendant for burglary of a vehicle. The trial court considered the subsequent charges pending against Defendant at sentencing, declined to sentence him as a youthful offender, and instead sentenced him to twelve years in prison. The Fourth District Court of Appeal affirmed Defendant’s sentence, concluding that the trial court did not violate Defendant’s due process rights during sentencing for the primary offense by considering his subsequent arrest without conviction. The Supreme Court quashed the Fourth District’s decision, holding that a trial court may not consider a subsequent arrest without conviction during sentencing for the primary offense. View "Norvil v. State" on Justia Law

After a jury trial, Defendant was convicted of sexual battery against a child by a person eighteen years of age or older and lewd and lascivious molestation on a child by a person eighteen years of age or older. The trial court sentenced Defendant to life imprisonment plus forty years and designated him a sexual predator. The First District Court of Appeal ultimately affirmed Defendant’s sentence. The First District then certified a question to the Supreme Court asking whether case law requires preservation of an evidentiary deficiency where the State proved only a lesser included offense and the sentence required for the greater offense would be unconstitutional as applied to the lesser offense. The Supreme Court answered the certified question in the affirmative but remanded the matter on the grounds that Defendant’s trial counsel rendered ineffective assistance by failing to move for judgment of acquittal of the greater offenses during or after trial. View "Monroe v. State" on Justia Law