Justia Florida Supreme Court Opinion Summaries

The State sought to revoke Defendant’s probation based upon Defendant's alleged illegal drug use in violation of the conditions of his probation. The Second District Court of Appeal reversed the trial court’s revocation order, holding that the probation officer’s testimony that Defendant failed a field drug test personally administered by the officer was not competent, nonhearsay evidence that Defendant had used an opiate in violation of his probation and that the only other evidence of the violation was hearsay. The Supreme Court quashed the Second District’s decision, holding (1) the probation officer testimony regarding the result of the field drug test was competent, nonhearsay evidence of a probation violation; and (2) this evidence, together with the hearsay evidence, was sufficient to establish that Defendant violated the conditions of his probation. View "State v. Queior" on Justia Law

Defendant was convicted of two counts of first-degree murder and sentenced to death for the murders. Defendant filed a motion to vacate his convictions and sentences, arguing that he was denied a fair guilt phase because of counsel’s deficient performance and that he was denied a fair penalty phase because counsel provided ineffective assistance. After an evidentiary hearing, the circuit court denied relief on all claims. The Supreme Court affirmed the postconviction court’s order denying postconviction relief on all claims, holding that Defendant’s counsel provided constitutionally effective assistance during both the guilt phase and the penalty phase. View "Rigterink v. State" on Justia Law

Defendant was indicted on two counts of first-degree murder. Defendant moved to suppress any statements he made to law enforcement and any evidence obtained as a result of those statements, asserting that he was in custody when he was questioned and was not read the Miranda warnings and that he was improperly denied access to his attorney. The trial court denied the motion to suppress. The Second District Court of Appeal reversed, holding (1) Defendant was not in custody when he initially confessed to the murders, but (2) once Defendant confessed and was read the Miranda warnings, he was in custody and should have been informed that the attorney retained on his behalf was at the sheriff’s office where Defendant was being interrogated and was available to speak to Defendant. The Supreme Court quashed the Second District’s decision and remanded, holding (1) when a person is questioned in a non-public location and an attorney retained on his behalf appears at the location, due process requires that law enforcement notify the person with regard to the presence and purpose of the attorney, regardless of whether the person is in custody; and (2) the Miranda violation in this case constituted harmful error. View "State v. McAdams" on Justia Law

After a jury trial, Defendant was convicted of one count of conspiracy to commit racketeering and one count of first-degree grand theft. After a sentencing hearing, the trial court ordered Defendant to serve ten years in prison followed by ten years of probation. The sentence, however, provided that if Defendant made a certain restitution payment within sixty days then his prison term would be reduced to eight years. The Fourth District Court of Appeal affirmed Defendant's convictions and sentences. The Supreme Court quashed the Fourth District’s decision, holding that Defendant's sentence violated his due process rights under the federal Constitution and that Defendant was entitled to resentencing. View "Noel v. State" on Justia Law

Petitioner, an inmate in state custody, filed in the Supreme Court a pro se petition for writ of mandamus. The petition was the twenty-first extraordinary writ petition or notice he had filed since 2008. The Supreme Court denied the petition and directed Petitioner to show cause why he should not be barred from filing any future pro se requests for relief and referred him to the Florida Department of Corrections for possible disciplinary action. Petitioner filed a response to the order to show cause and a motion seeking rehearing. The Supreme Court denied the motion and concluded that Petitioner failed to show cause why sanctions should not be imposed against him for his repeated misuse of the Court’s limited judicial resources and concluded that the petition filed by Petitioner was a frivolous proceeding. Accordingly, the Court directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner unless such filings are signed by a member in good standing of The Florida Bar. View "Blaxton v. State" on Justia Law

Noel Plank, a prospective juror, was found in direct criminal contempt for coming to the courthouse drunk and thereby disrupting the jury selection and distracting the other jurors. The trial judge sentenced Plank to thirty days in jail. Plank appealed, arguing that the trial court erred by not appointing him counsel or giving him an opportunity to seek counsel for the contempt proceeding. The Court of Appeal affirmed. At issue on appeal was whether an individual is entitled to counsel in direct criminal contempt proceedings before incarceration is imposed as punishment. The Supreme Court quashed the Court of Appeal’s decision and directed that Plank’s conviction for direct criminal contempt be vacated, holding (1) there is no requirement to appoint counsel in direct criminal contempt proceedings where a defendant is incarcerated for less than six months; but (2) because the allegedly contemptuous conduct for which Plank was incarcerated did not involve conduct that occurred only in the presence of the court, the trial court erred in classifying the conduct as direct criminal contempt. View "Plank v. State" on Justia Law

Defendant pleaded guilty to first-degree murder. The trial court sentenced Defendant to death after concluding that the aggravating circumstances outweighed the mitigating circumstances. The Supreme Court affirmed, holding (1) the trial court did not err in accepting Defendant’s waiver of the presentation of mitigating circumstances without appointing special counsel to investigate and present such evidence on his behalf; (2) the presentence investigation report considered by the trial court was sufficiently comprehensive to satisfy the applicable requirements; (3) the trial court did not violate Defendant’s procedural rights by preparing the sentencing order before the sentencing hearing; (4) the trial judge properly discussed in the sentencing order the evidence of Defendant’s motive in committing the murder; (5) Defendant’s guilty plea was knowing and voluntary; and (6) the sentence of death was proportional. View "Robertson v. State" on Justia Law

Petitioner was convicted of aggravated assault and cocaine possession, among other criminal offenses, and was sentenced to fifteen years in prison. The court of appeal affirmed Petitioner’s convictions and sentences. Petitioner began filing with the Supreme Court in 2011 and, since that time, filed twenty-three extraordinary writ petitions or notices, none of which were successful. The petition in this case was a pro se petition for writ of mandamus filed with the Supreme Court. The Supreme Court denied the petition and retained jurisdiction to pursue possible sanctions against Petitioner based upon his numerous meritless and inappropriate filings. The Supreme Court imposed sanctions, concluding that Petitioner failed to show cause why sanctions should not be imposed against him for his repeated misuse of the Court’s limited judicial resources and directed the Clerk of Court to reject any future pleadings or requests for relief submitted by Petitioner regarding his criminal case unless such filings are signed by a member in good standing of the Florida Bar. View "Green v. State" on Justia Law

After a jury trial, Defendant was convicted of one count of second-degree murder and one count of shooting at, into, or within an occupied vehicle. During trial, Defendant asserted that he shot at the vehicle in which the victim was a passenger both in self-defense and defense of others. On appeal, Defendant argued for the first time that the jury instruction conflicted with regard to the duty to retreat. The court of appeal reversed Defendant’s convictions and remanded for a new trial, holding that the instructions at issue were contradictory and negated Defendant’s defense of self-defense and defense of others. The Supreme Court quashed the decision below, holding that the instructions at issue clearly stated the law and were not confusing, misleading, or contradictory with regard to the duty to retreat where there is a question of fact as to who was the initial aggressor. Remanded. View "State v. Floyd" on Justia Law

Defendant was charged with possession with intent to sell or deliver and possession of more than twenty grams of cannabis. Defendant appealed, arguing that the trial court erred in refusing to grant his motion for judgment of acquittal. Recognizing that Defendant was convicted under a theory of constructive possession, the court of appeal affirmed Defendant’s conviction, finding that the circumstantial evidence standard should apply only where both elements of constructive possession are proven solely by circumstantial evidence. The Supreme Court approved the court of appeal’s decision and upheld Defendant’s conviction for constructive possession, holding (1) the circumstantial evidence standard of review continues to apply in Florida; (2) with direct evidence of dominion and control, Defendant’s case could not be considered wholly circumstantial, and therefore, the circumstantial evidence standard of review does not apply; and (3) the State produced sufficient evidence that a rational jury could find the elements of the crime beyond a reasonable doubt. View "Knight v. State" on Justia Law