Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of manslaughter with a firearm, attempted home invasion robbery with a firearm, and armed burglary. Prior to sentencing, the State informed the trial court that dual convictions for attempted home invasion robbery and armed robbery presented double jeopardy concerns. The parties subsequently debated as to which conviction should be vacated. The trial court accepted the position of the State and vacated the attempted home invasion robbery conviction, which carries a lesser sentence. The Second District Court of Appeal concluded that the lesser offense of armed burglary should have been vacated. The Supreme Court approved the decision below, holding that when a defendant is found guilty of two offenses and adjudication of the defendant as guilty for both offenses would violate double jeopardy protections, the lesser offense as defined by Pizzo v. State should be vacated. View "State v. Tuttle" 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 vacated the convictions and sentences of death, holding (1) the trial court did not err in denying Defendant’s motion for judgment of acquittal on the charge of premeditated first-degree murder; (2) the trial court did not err in instruction the jury on burglary as the underlying felony; but (3) numerous errors occurred during the trial, including the following: (i) the trial court erred in permitting a law enforcement officer to opine that a voice heard on a 911 call-back recording belonged to Defendant even though the detective had no prior knowledge of Defendant and no expertise in voice identification, (ii) the State insinuated unsubstantiated and incriminating facts when it cross-examined Defendant, and (iii) the prosecutor gave improper closing arguments. Based on these cumulative errors, Defendant was entitled to a new trial. View "Evans v. State" on Justia Law

During a dissolution of marriage proceeding, Wife filed a motion for contempt for Husband’s failure to deliver one of the couple’s dogs into her custody. The trial court issued an order directing Husband to appear. Husband did not appear for the hearing on the motion for contempt. The trial court held Husband in civil contempt for failing to transfer the dog and ordered him to comply with the order. Husband still did not transfer the dog, and another motion for contempt was filed. Husband was not present at a subsequent hearing on the motion. The trial court held Respondent in civil contempt for failing to appear and also held him in criminal contempt. During the appeal of the criminal contempt order, the State recommended that the failure to appear in court be treated as indirect, rather than direct, criminal attempt. The Court of Appeal concluded that direct criminal contempt applied but reversed the conviction based on insufficient evidence. The Supreme Court approved the Court of Appeal’s decision to the extent that it reversed the conviction but held that direct criminal contempt did not apply to this case because when a failure to appear results in criminal contempt proceedings, a charge of indirect criminal contempt is applicable. View "State v. de la Portilla" on Justia Law

Tai Pham was convicted of first-degree murder, attempted first-degree murder, armed kidnapping, and armed burglary. The trial court entered a sentence of death. The Supreme Court affirmed the convictions and sentences. Pham later filed a motion to vacate judgment of conviction and sentence of death, raising several claims. The circuit court summarily denied some claims and held an evidentiary hearing on the remaining claims. Thereafter, the court denied relief. Pham appealed and also filed a petition for a writ of habeas corpus. The Supreme Court affirmed, holding (1) Pham failed to establish that he received ineffective assistance of counsel during either the guilt or the penalty phase; and (2) appellate counsel likewise did not provide ineffective assistance. View "Pham v. State" on Justia Law

Petitioner was convicted of arson and second-degree murder and sentenced in 2012 to life in prison on both counts. Petitioner subsequently filed more than thirty-five other extraordinary writ petitions or notices in the Supreme Court pertaining largely to four proceedings that were either frivolous, devoid of merit, or inappropriate for consideration. In this mandamus petition, Petitioner challenged the Court of Appeal’s denial of his ineffective assistance of appellate counsel petition and its imposition of pro se filing sanctions. 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. Petitioner filed a response to the order to show cause, which the Court struck as untimely. The Supreme Court then exercised its inherent authority to sanction Petitioner for abusing the judicial process and burdening the Court’s limited judicial resources, directing the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner that related to the four proceedings unless such filings were signed by a member in good standing of the Florida Bar. View "Casey v. State" on Justia Law

Petitioner was convicted of two counts of second-degree murder with a firearm and two counts of robbery with a firearm causing great bodily harm and was sentenced to a term of fifty-five years in prison. Three years later, the State moved to reduce or suspend Petitioner’s sentence pursuant to Fla. Stat. 921.186, the substantial assistance statute, explaining that it sought Petitioner’s assistance in its prosecution of a codefendant. After a hearing, the trial court denied the State’s motion. Petitioner appealed. The State countered that the order was not appealable. The Second District Court of Appeal affirmed the trial court’s decision, concluding that it had jurisdiction to review the trial court’s order denying the section 921.186 motion but that the trial court in this case misapplied the statute. The Supreme Court quashed the decision below, holding (1) orders denying relief under section 921.186 are appealable; and (2) the trial court considered improper reasons for denying the section 921.186 motion and thus abused its discretion in denying the motion. View "McFadden v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder, first-degree felony murder with a weapon, burglary of an occupied dwelling while armed, and dealing in stolen property. The trial court sentenced Appellant to death. The Supreme Court affirmed Appellant’s conviction of first-degree murder and upheld his death sentence, holding (1) the trial court erred in finding the avoid arrest aggravator and the cold, calculated and premeditated aggravator, but the errors were harmless; (2) Appellant’s death sentence was proportional; (3) the trial court did not abuse its discretion in denying Appellant’s motion to continue the penalty phase to set the order of penalty phase witnesses; (4) the trial court did not abuse its discretion in denying the defense funds to appoint a mitigation specialist; (5) the trial court appropriately performed the individualized sentencing required for death penalty cases; (6) the trial court did not err in denying Appellant’s motion to suppress his videotaped confession; (7) the evidence was sufficient to support the convictions; and (8) the felony murder aggravator is constitutional. View "Middleton v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder and robbery with a firearm or other deadly weapon. The trial court imposed a sentence of death for the murder conviction and a life sentence for the conviction for robbery with a firearm or other deadly weapon. The Supreme Court affirmed, holding (1) the prosecutor made an improper comment during closing arguments, but the comment did not rise to the level of fundamental error; (2) the heinous, atrocious, or cruel aggravating circumstance was properly applied to Defendant; (3) the admission of victim impact statements into evidence was permissible; (4) the trial court did not err in rejecting the statutory mitigator that Defendant’s ability to conform his conduct to the requirements of the law was substantially impaired; (5) Defendant’s death sentence was proportional; (6) Florida’s death penalty statutory scheme is not unconstitutional under Ring v. Arizona; and (7) there was competent, substantial evidence to support Defendant’s convictions. View "Jordan v. State" on Justia Law

Defendant pled guilty to first-degree murder and robbery with a weapon. The trial court sentenced Defendant to death. The Supreme Court affirmed the convictions and sentences on appeal. Defendant subsequently filed an amended Fla. R. Crim. P. 3.851 motion raising four claims alleging ineffective assistance of counsel. The trial court denied all claims after an evidentiary hearing. The Supreme Court affirmed the postconviction court’s denial of relief under Rule 3.851, holding that Defendant failed to demonstrate that counsel were ineffective at either the guilt or penalty phases of his trial. View "Guardado v. State" on Justia Law

Appellant was convicted of four counts of first-degree murder and sentenced to death for each murder. After Governor Scott signed the death warrant Appellant filed a third successive motion for postconviction relief, claiming, inter alia, that Florida’s death penalty statute is unconstitutional. Appellant also filed extensive public records requests with several entities. Appellant was provided with some, but not all, of the requested records. The circuit court summarily denied Appellant’s third successive postconviction motion. Appellant subsequently filed a fourth successive postconviction petition, asserting, inter alia, that Florida’s lethal injection protocol is unconstitutional because of the use of midazolam. The circuit court denied Appellant’s fourth successive motion for postconviction relief. The Supreme Court affirmed the denial of Appellant’s third and fourth successive motions for postconviction relief, as well as the circuit court orders sustaining the objections to the public records requests, holding (1) Appellant’s challenge to the use of midazolam failed; (2) Appellant’s public records challenges were without merit; and (3) Appellant was not entitled to relief on the remainder of his claims. View "Correll v. State" on Justia Law