Justia Florida Supreme Court Opinion Summaries

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

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

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

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

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

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

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