Justia Florida Supreme Court Opinion Summaries

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

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