Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was acquitted of lewd and lascivious molestation but convicted of misdemeanor battery - a lesser included offense of the molestation charge. As a special condition of his probation Defendant was ordered to undergo mentally disordered sex offender (MDSO) therapy. Defendant appealed, challenging the sex offender therapy as a condition of probation. The Third District Court of Appeal upheld the trial court’s imposition of MDSO therapy, holding (1) sex offender therapy as a condition of probation is not restricted by statute to only certain enumerated sexual offenses; and (2) the imposition of the condition comported with the standards governing probation announced by the Supreme Court in Biller v. State. The Supreme Court reversed, holding (1) the imposed probation condition was not limited to certain enumerated sex offenses; but (2) the special condition was invalid based on the Court’s decision in Biller because it did not satisfy any of the Biller factors. View "Villanueva v. State" on Justia Law

After a trial, Defendant was found guilty of murder, sexual battery, kidnapping, burglary, and grand theft. Defendant was sentenced to death for the murder. The Supreme Court affirmed the convictions and sentences. Defendant subsequently filed a motion for postconviction relief, raising seven claims of error. Defendant also filed a petition for a writ of habeas corpus. The trial court denied relief. The Supreme Court affirmed the denial of postconviction relief and denied habeas relief, holding (1) the postconviction court did not err in finding that counsel did not provide constitutionally ineffective assistance during the guilt phase or penalty phase; (2) the postconviction court did not err in denying Defendant’s Brady claim; (3) appellate counsel did not provide ineffective assistance; and (4) Defendant was not entitled to relief under Hurst v. Florida. View "Brant v. State" on Justia Law

Petitioner pled no contest to aggravated child abuse and simple child abuse. Petitioner was sentenced to a term of imprisonment and drug offender probation. The probation contained a special condition prohibiting Petitioner from associating with anyone who was illegally using drugs. Petitioner appealed, arguing that the special condition was improperly vague. The Court of Appeal upheld the special condition. Petitioner then petitioned the Supreme Court for review. The Court approved the Court of Appeal’s decision, holding (1) Petitioner’s special condition of probation, “you will not associate with anyone who is illegally using drugs,” is not unconstitutionally vague; but (2) to prove a violation of the condition the State must prove by a preponderance of the evidence the probationer’s knowledge that the person with whom he or she associated was illegally using drugs at the time of the violation. View "Demott v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder. The trial court sentenced Defendant to death for both murders. The Supreme Court affirmed Defendant’s convictions and sentences on appeal. Defendant subsequently filed an amended motion to vacate his judgment and sentences, alleging ineffective assistance of counsel during both the guilt phase and penalty phase of trial. The postconviction court granted Defendant a new penalty phase, concluding that counsel provided ineffective assistance during the penalty phase and that Defendant was deprived of a fair trial during the penalty phase by the cumulative effect of the errors. The court denied Defendant’s remaining claims. Both the State and Defendant appealed. The Supreme Court affirmed the postconviction court’s order and remanded for a new penalty phase proceeding, holding (1) competent, substantial evidence supported the postconviction court’s findings that Defendant was prejudiced by the deficient performance of his penalty phase counsel; and (2) the postconviction court did not err in finding that Defendant’s trial counsel were not unconstitutionally ineffective during the guilt phase of his trial. View "State v. Bright" on Justia Law

Defendant pleaded guilty to two counts of first-degree murder and one count of attempted first-degree murder. The trial court sentenced Defendant to death for the murders and to life imprisonment for the attempted murder. On appeal, Defendant’s principal claim was that the trial court impermissibly allowed the State to enter into evidence DVDs and photographs derived from surveillance footage without proper authentication. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion regarding the authentication of the DVDs and still photographs; (2) the trial court incorrectly applied the law regarding the avoid arrest aggravating circumstance with respect to one of the murders, but additional evidence supported the inference that Defendant acted with the intent to eliminate witnesses and avoid prosecution; (3) the sentencing order did not violate the requirements established in Campbell v. State; (4) the death sentence was proportionate in this case; (5) substantial evidence supported Defendant’s convictions; and (6) Defendant was not entitled to relief pursuant to Hurst v. Florida. Remanded for entry of a written order of competency. View "Mullens v. State" on Justia Law

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