Justia Florida Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Blaxton v. State
Defendant, an inmate in state custody, filed in the Supreme Court a pro se petition for writ of mandamus. The petition was the thirty-first extraordinary writ petition or notice he had filed in approximately seven years. The Supreme Court denied the petition and directed Defendant 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. Defendant filed a response to the order to show cause and a motion seeking rehearing. The Supreme Court denied the motion and concluded that Defendant failed to show cause why sanctions should not be imposed against him for his repeated misuse of the Court’s limited judicial resources, holding (1) neither Defendant’s response to the show cause order nor his motion for rehearing contained a justification for his repeated misuse of the Court’s limited judicial resources; and (2) because Defendant’s petitions were frivolous, the Clerk of Court is hereby directed to reject any future pleadings or other requests for relief submitted by Defendant unless such filings are signed by a member in good standing of the Florida Bar. View "Blaxton v. State" on Justia Law
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Criminal Law
Long v. State
Appellant pleaded guilty to murder and was sentenced to death. Appellant later filed a successive motion for postconviction relief, alleging that newly discovered evidence rendered his guilty plea invalid. The postconviction court summarily denied Appellant’s successive postconviction motion as time-barred because the newly discovered evidence could have been ascertained earlier with the exercise of due diligence. The Supreme Court affirmed, holding (1) because Appellant failed to timely file this motion after he first discovered the information at issue, the postconviction court’s summary denial was not in error; and (2) even if Appellant’s successive postconviction motion was timely filed, Appellant failed to establish that he was entitled to relief. View "Long v. State" on Justia Law
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Criminal Law
Allred v. State
Appellant was indicted on charges of two counts of first-degree premeditated murder. Appellant entered written and oral guilty pleas to all charges. Appellant subsequently waived his right to a penalty phase jury and his right to be present in the penalty phase. Appellant was sentenced to death for the murders. The Supreme Court affirmed the trial court’s judgment. Appellant later filed a motion for postconviction relief, alleging ineffective assistance of counsel, among other claims. The circuit judge denied all claims. The Supreme Court affirmed, thus denying Appellant’s claims that trial counsel provided constitutionally ineffective assistance and Appellant’s challenges to the constitutionality of several of Florida’s death penalty provisions. View "Allred v. State" on Justia Law
Bolin v. State
Appellant was scheduled for execution on January 7, 2016 for first degree murder. In 2014, Appellant filed an amended first successive postconviction motion. The circuit court denied the amended petition. Appellant moved for rehearing and subsequently filed a second successive motion for postconviction relief. The circuit court denied both the motion for rehearing and the second successive motion for postconviction relief. The Supreme Court affirmed the circuit court’s orders denying relief, holding that the circuit court (1) did not err in denying Appellant’s newly discovered evidence claims; (2) properly denied Appellant’s claim that the State knowingly suppressed information in violation of Brady v. Maryland; and (3) properly denied Appellant’s claim that the Governor’s discretion to select condemned inmates for execution is unconstitutional. View "Bolin v. State" on Justia Law
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Criminal Law
Boyd v. State
Lucious Boyd was convicted of first-degree murder and sentenced to death. Boyd filed a motion to vacate his conviction and sentence. The circuit court denied relief. Boyd appealed the circuit court’s order denying postconviction relief and also petitioned for a writ of habeas corpus. As to Boyd’s postconviction relief claims, the Supreme Court held (1) Boyd failed to show that he was entitled to a new trial on his claims of actual juror bias; and (2) Boyd was not entitled to relief on his ineffective assistance of counsel claims. The Court also denied Boyd’s petition for writ of habeas corpus. View "Boyd v. State" on Justia Law
Oats v. State
Defendant was tried and convicted of the 1979 robbery of a convenience store and the first-degree murder of the store clerk. Defendant later filed a motion seeking to vacate his death sentence on the ground that he is intellectually disabled. After an evidentiary hearing, the circuit court denied the motion, concluding that Defendant was not intellectually disabled because he was unable to establish that his intellectual disability manifested prior to the age of eighteen - one of the three required prongs in Florida’s statutory test for determining an intellectual disability. The Supreme Court reversed, holding (1) in light of the United States Supreme Court’s decision in Hall v. Florida, the circuit court’s order should have addressed all three prongs of the intellectual disability test rather than a single factor; (2) the circuit court erred in concluding that Defendant failed to meet his burden of establishing his intellectual disability without considering or weighing all of the testimony that Defendant presented; and (3) the circuit court erred in other aspects of its legal analysis. Remanded. View "Oats v. State" on Justia Law
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Criminal Law
Rodriguez v. State
Defendant was arrested after law enforcement officers discovered marijuana plants growing in Defendant’s home. The officers did not make any efforts to obtain a search warrant before entering the home. Defendant filed a motion to suppress. The circuit denied denied the motion to suppress, concluding that the inevitable discovery doctrine applied in this case. Defendant subsequently entered a guilty plea and reserved the right to appeal the suppression issue. The Court of Appeal affirmed, finding that the trial court properly applied the inevitable discovery doctrine. The Supreme Court reversed, holding that, under the totality of the evidence, the lower courts improperly applied the inevitable discovery doctrine, and the trial court should have suppressed the evidence obtained from the illegal search. View "Rodriguez v. State" on Justia Law
Orme v. State
After a jury trial, Roderick Orme was convicted of premeditated or felony murder, robbery, and sexual battery. The trial judge sentenced Orme to death. The Supreme Court found defense counsel ineffective for failing to investigate further Orme’s diagnosis of bipolar disorder with respect to the penalty phase and ordered a new penalty phase. After a new penalty phase, the trial court again sentenced Orme to death, finding three aggravating factors. The Supreme Court affirmed. Orme later filed the instant motion for postconviction relief, bringing four claims of ineffective assistance of counsel. After a hearing, the postconviction court denied all of Orme’s postconviction claims. Orme appealed, raising four claims of ineffective assistance of resentencing phase counsel and one claim of ineffective assistance of postconviction. Orme also petitioned the Supreme Court for a writ of habeas corpus, alleging ineffective assistance of appellate counsel. The Supreme Court denied relief on all claims, holding that Orme failed to demonstrate ineffective assistance of resentencing phase counsel as to any of his claims and failed to demonstrate ineffective assistance of appellate counsel. View "Orme v. State" on Justia Law
Crews v. State
In 2012, the State charged Petitioner, a public school teacher, with sexual offenses against minors over the age of twelve, including eight counts charging second- or third-degree felonies alleged to have been committed between 2001 and 2006. These charges would have been barred by the three-year statute of limitations applicable to second- and third-degree felonies, but the State charged that when Petitioner committed the offenses, he was a public employee who engaged in “misconduct in office” under Fla. Stat. 775.15(3)(b), which extended the limitation period. Petitioner filed a motion to dismiss all eight charges on the ground that the statute of limitations had expired and the provision that extended the limitation period did not apply. The trial court denied the motions to dismiss. Petitioner then pleaded nolo contendere, reserving his right to appeal the denial of his motions to dismiss. The trial court adjudicated Petitioner guilty of the charged offenses. The court of appeal affirmed. The Supreme Court affirmed approved the decision of the court of appeal, holding that the offenses at issue were properly regarded as “misconduct in office,” and the statute of limitations extension provision was properly applied in this case. View "Crews v. State" on Justia Law
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Criminal Law
Rivera v. State
Defendant was convicted and sentenced to death for the first-degree murder of an eleven-year-old girl. The Supreme Court affirmed the conviction and sentence. This appeal concerned Defendant’s amended successive Fla. R. Crim. P. 3.850 motion in which Defendant alleged four claims. The trial court summarily denied all claims. The Supreme Court affirmed the denial of one claim but remanded for an evidentiary hearing on the remaining claims. On remand, the trial court again denied all claims. The Supreme Court affirmed, holding (1) Defendant failed to establish a Giglio violation; (2) Defendant failed to establish a Brady violation, and Defendant’s ineffective assistance of trial counsel claim, pled as an alternative to his Brady claim, was procedurally barred; and (3) because newly discovered DNA evidence was not of such a nature that it would probably produce an acquittal on retrial, relief on Defendant’s newly discovered DNA evidence claim was properly denied. View "Rivera v. State" on Justia Law