Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of four counts of aggravated assault with a firearm, during the course of which he actually possessed and discharged a firearm. The convictions arose from a single episode during which Defendant pointed a gun at four men. The trial court imposed consecutive minimum terms of imprisonment for each count. The Court of Appeal affirmed, concluding that the trial court was required to impose consecutive sentences under Fla. Stat. 775.087(2)(d). The Supreme Court quashed the Court of Appeal’s decision, holding a trial court is not required under section 775.087(2)(d) to impose consecutive minimum terms of imprisonment for multiple offenses when the offenses arise from a single criminal episode. Remanded. View "Williams v. State" on Justia Law

Defendant was convicted of both sexual battery on a person under twelve years of age and lewd or lascivious molestation on a person under twelve years of age for a single act. Defendant appealed, arguing that his dual convictions violated his constitutional protection against double jeopardy. The court of appeal concluded that convictions for both lewd or lascivious molestation and sexual battery arising from the same act do not violate the constitutional prohibition against double jeopardy. The Supreme Court affirmed, holding that Defendant’s separate sentences for capital sexual battery and lewd or lascivious molestation arising from a single act do not violate the prohibition against double jeopardy. View "Roughton v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder, attempted first-degree murder, and related crimes. The trial court sentenced Defendant to death. The Supreme Court affirmed the conviction and death sentence. Appellant later filed a motion for postconviction relief, which the trial judge denied. Appellant appealed and also petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court remanded for a new penalty phase and denied Appellant’s habeas petition, holding (1) trial counsel was ineffective for failing to investigate and present mitigation, including Appellant’s background and intellectual functioning, at the penalty phase; and (2) Appellant’s claims in his habeas petition were unavailing. View "Salazar v. State" on Justia Law

Appellant was found guilty of the first-degree murder and aggravated child abuse of her three-year-old son, Lazaro. The Supreme Court vacated Appellant’s convictions and remanded for a new trial, holding that the pervasiveness and the cumulative effect of the prosecutor’s multiple improper closing arguments in the guilt phase, which repeatedly invoked “justice for Lazaro” and appealed to the passions of the jury, constituted impermissible prosecutorial misconduct and deprived Appellant of a fair trial. Moreover, most of the improper comments were objected to, and those objections were overruled by the trial court, increasing the prejudicial effect of the comments. View "Cardona v. State" on Justia Law

Fla. Stat. 790.23(1) makes it a criminal offense for a person to own or have in his care, custody, possession, or control any firearm if that person has been convicted of a felony in a Florida court. The United States Court of Appeals for the Eleventh Circuit asked the Supreme Court to determine if, under Florida law, a person is “convicted” for purposes of that statute if the person has pleaded guilty to a felony offense but adjudication for that offense has been withheld. The Supreme Court answered the certified question in the negative, holding that, for purposes of the statute, a guilty plea for a felony for which adjudication was withheld does not qualify as a conviction under section 790.23(1)(a). View "Clarke v. United States" on Justia Law

Defendant was convicted of burglary with a firearm after he removed firearms from the victim’s storage unit. The victim testified at trial that Defendant did not have permission to enter the storage unit without him. After Defendant’s trial, the victim wrote a letter to the trial court purporting to provide a possible motive for Defendant’s action. Defendant filed a motion for new trial asserting that the letter qualified as newly discovered evidence. The trial court denied the motion, concluding that the letter did not constitute a recantation. The court of appeal affirmed, concluding that the letter did not contradict the victim’s trial testimony and did not contain evidence that disproved one of the elements of burglary with a firearm. The Supreme Court affirmed, holding that the trial court did not err in denying Defendant’s motion for a new trial without an evidentiary hearing even though the trial court and court of appeal misstated the appropriate standard for analyzing whether a recantation constitutes newly discovered evidence. View "Koo v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder. Defendant was sentenced to death. The Supreme Court affirmed. Defendant subsequently filed a motion for postconviction relief, alleging ineffective assistance of trial counsel, due process violations, and a claim under Ring v. Arizona. The trial court denied postconviction relief. Defendant appealed the denial of relief and also filed a petition for a writ of habeas corpus and for extraordinary relief. The Supreme Court reversed the trial court’s denial of postconviction relief, holding that Defendant’s counsel provided ineffective assistance to the prejudice of Defendant. Remanded for a new trial. View "Ibar v. State" on Justia Law

This matter involved the pro se petition for writ of mandamus filed by Petitioner, an inmate in state custody. This petition was one of twenty-one extraordinary writ petitions or notices Petitioner had filed with the Supreme Court since 2008. The Supreme Court denied Petitioner’s petition and expressly retained jurisdiction to pursue possible sanctions against him based on the number of his frivolous and meritless filings. The Supreme Court 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 directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner unless the filings were signed by a member in good standing of The Florida Bar. View "Blaxton v. State" on Justia Law

Appellant, a prisoner under sentence of death, filed a successive motion for postconviction relief, claiming that newly discovered evidence rendered his guilty plea invalid. The postconviction court summarily denied Appellant’s successive postconviction motion as time-barred on the grounds that the newly discovered evidence was information that could have been ascertained with the exercise of due diligence. The Supreme Court affirmed, holding that the postconviction court’s summary denial was proper, as Appellant failed to timely file this motion and, further, Appellant could not demonstrate a reasonable probability that, but for the newly discovered evidence, he would not have pleaded guilty and would have insisted on going to trial. View "Long v. State" on Justia Law

Respondent was convicted of burglary of a dwelling with a battery and aggravated battery and sentenced to life in prison. Respondent later filed a postconviction motion under Fla. R. Crim. P. 3.850 raising four grounds for relief. As his first ground for relief, Respondent alleged that trial counsel was ineffective in failing to hire an ophthalmologist expert to rebut the State’s claim that the victim suffered permanent eye damage as an element of aggravated battery. The State responded that the claim in ground one was insufficiently pled because it did not name the witness that should have been called and did not allege that the witness would have been available to testify at trial. The trial court struck the 3.850 motion. The district court reversed, concluding that Respondent was not required to provide the name of an ophthalmologist expert and that Respondent’s postconviction motion was facially sufficient. The Supreme Court affirmed, holding that a 3.850 motion alleging that trial counsel was ineffective for failing to consult or present an expert in a named field of expertise need not, in every case, name a specific expert and attest that the specific expert would have been available to testify at trial. View "State v. Lucas" on Justia Law