Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of first-degree murder on theories of both premeditation and felony murder and related crimes. The trial court sentenced Defendant to death, finding that the aggravating factors outweighed the mitigating factors. The Supreme Court affirmed, holding (1) the trial court did not err in assigning weight to the felony probation aggravator; (2) the trial court did not err in applying the heinous, atrocious, or cruel aggravator to Defendant; (3) the trial court did not err in instructing the jury on attempted voluntary manslaughter; (4) the evidence was sufficient to support Defendant’s convictions for robbery, attempted robbery, and arson; (5) the trial court did not abuse its discretion in responding to a jury question during deliberations; (6) even if the court erred in admitting hearsay statements into evidence, there was no reasonable possibility that the admission of these statements contributed to the conviction; and (7) Defendant’s death sentence was a proportionate sentence. View "Cannon v. State" on Justia Law

In 2004, Defendant was convicted of first-degree murder. The trial court entered an order sentencing Defendant to death. The Supreme Court affirmed on appeal. Defendant filed a motion for postconviction relief under Fla. R. Crim. P. 3.851 alleging ineffective assistance of counsel and a Brady/Giglio claim. The court denied Defendant’s motion to vacate his conviction and sentence in its entirety. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus, alleging ineffective assistance of counsel. The Supreme Court (1) affirmed the order denying postconviction relief, holding that the postconviction court did not err in its rulings; and (2) denied Defendant’s petition for a writ of habeas corpus, holding that Defendant failed to establish that he received ineffective assistance of counsel. View "Hernandez v. State" on Justia Law

In 2005, Defendant was convicted of first-degree murder, attempted armed robbery, and grand theft of a motor vehicle. The trial court sentenced Defendant to death for the murder conviction. The Supreme Court affirmed on appeal. In 2009, Defendant filed a second amended motion for postconviction relief, alleging several claims. The postconviction court denied Defendant’s motion to the extent it requested a new guilt phase but granted the motion to the extent that it requested a new penalty phase. Defendant appealed and, in addition, filed a petition for a writ of habeas corpus, asserting four claims. The Supreme Court affirmed the postconviction court’s order that denied Defendant’s request for a new guilt phase trial and denied his petition for a writ of habeas corpus, holding (1) the postconviction court did not err in its rulings; and (2) Defendant was not entitled to relief on his habeas corpus claims. View "Blake v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder and related crimes. The trial court sentenced Defendant to death for the murders. Defendant later filed a motion to vacate his conviction and sentence. The circuit court treated Defendant’s filing as an initial motion pursuant to Fla. R. Crim. P. 3.851 and summarily denied all of his claims for postconviction relief. Defendant appealed the denial of his motion and, in addition, petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court (1) affirmed the circuit court’s summary denial of relief, holding that while Defendant’s claims of trial court error were insufficiently pleaded and without merit, it was necessary to address the unusual procedure employed for jury selection in Defendant’s trial; and (2) denied the petition for writ of habeas corpus, holding that appellate counsel was not ineffective during Defendant’s direct appeal. View "Hojan v. State" on Justia Law

After a jury trial, Defendant was found guilty of the first-degree murder of Debra Pearce. Pearce was stabbed in her kitchen in 2004. The murder remained unsolved until 2008 when DNA from a hair found on Pearce’s body and a fingerprint found in blood on the sink above Pearce’s body were both matched to Defendant. The Supreme Court affirmed, holding (1) the challenges Defendant raised with respect to the identification and timing of the sink fingerprint, the hair, and his participation in the murder were issues that were properly presented to and decided by the jury; (2) Defendant’s claim that the evidence was insufficient to establish that he was an active participant in the murder was not preserved for appeal; (3) the State presented sufficient evidence to support the jury finding of premeditation; (4) any error in the prosecutor’s closing statements was not fundamental; (5) the especially heinous, atrocious, or cruel aggravating circumstance was properly applied; (6) the death sentence was proportionate in this case; and (7) the Court declines to revisit the decisions holding that Florida’s capital sentencing scheme does not violate the federal Constitution under Ring v. Arizona or Apprendi v. New Jersey. View "Jackson v. State" on Justia Law

Defendant in this criminal case was represented by an attorney who also represented Defendant’s codefendant. At issue on appeal was whether Defendant’s “waiver of the right to conflict-free trial counsel was invalid.” The district court of appeal reversed Defendant’s conviction, concluding that the trial court failed to conduct a sufficient inquiry when Defendant consented to his attorney representing both him and his codefendant and that the error was not harmless. The State appealed, arguing that a waiver of the right to conflict-free counsel is only required when there is an actual conflict of interest and that an attorney’s representation of two or more codefendants does not necessarily create an actual conflict of interest. The Supreme Court quashed the decision of the district court of appeal and remanded the case with directions that Defendant’s conviction be affirmed, holding (1) some adverse or detrimental effect on the representation is required in order to establish an actual conflict of interest; and (2) because there was no finding of an actual conflict of interest in this case, there was no need for a waiver. View "State v. Alexis" on Justia Law

Fla. Stat. 776.032, the “Stand Your Ground” law, provides immunity from prosecution when a defendant has used force as permitted by Fla. Stat. 776.012, 776.013, or 776.031. Defendant in this case was charged with aggravated assault with a firearm. Defendant filed a motion to dismiss, claiming immunity from prosecution under the Stand Your Ground law and sought a pretrial evidentiary hearing on his motion to dismiss. The trial court ultimately denied the motion to dismiss. Defendant subsequently filed a writ of prohibition in the Fifth District Court of Appeal. The Fifth District ruled (1) the defendant has the burden of proving at the pretrial evidentiary hearing that he is entitled to Stand Your Ground immunity, and (2) Defendant was not entitled to such immunity in this case. The Supreme Court approved the Fifth District’s opinion, holding that the Fifth District correctly determined that the defendant bears the burden of proof, by a preponderance of the evidence, to demonstrate the defendant’s entitlement to immunity at the pretrial evidentiary hearing under the Stand Your Ground law. View "Bretherick v. State" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed the conviction and death sentence, holding (1) the trial court did not err in denying Defendant’s motion for judgment of acquittal because there was competent, substantial evidence to support Defendant’s conviction; (2) the trial court did not err in denying a motion for mistrial after a witness marginally referenced another investigation that was occurring in a different jurisdiction; (3) the trial court did not err in permitting an inmate to testify as to the threat that Defendant made to a witness through the inmate; (4) the trial court did not err in denying Defendant’s motion for a continuance; (5) the trial court did not err in finding that the murder was especially heinous, atrocious, or cruel; (6) the trial court did not err in rejecting two proposed statutory mitigators; and (7) the sentence of death was proportional in this case. View "Smith v. State" on Justia Law

Appellant pled guilty to first-degree murder. The trial court imposed a death sentence after weighing the aggravating circumstances against the mitigating circumstances. The Supreme Court affirmed Appellant’s conviction for first-degree murder and his sentence of death, holding (1) Appellant’s guilty plea was knowingly, intelligently, and voluntarily entered; (2) the trial court did not err in instructing the jury on the especially heinous, atrocious, or cruel aggravator; (3) the trial court did not err in permitting Appellant, who was proceeding pro se, to elicit testimony pertaining to his future dangerousness; (4) the trial court did not commit fundamental error in permitting the medical examiner to testify in a manner that implicated the Golden Rule; and (5) the sentence of death was proportionate in this case. View "Doty v. State" on Justia Law

Appellant was convicted of the 2002 first-degree murders of three individuals. The trial court sentenced Defendant to death for two of the murders and to life imprisonment for the third murder. The Supreme Court affirmed the convictions and sentences. This appeal concerned Appellant’s initial postconviction motion in which he asserted that his trial counsel was ineffective in failing to call experts to testify as to mental health mitigation at trial or at the subsequent Spencer hearing and in failing to move for a change of venue. The circuit court denied postconviction relief. The Supreme Court affirmed, holding (1) Appellant failed to establish ineffective assistance of counsel as to his first claim; and (2) the circuit court correctly denied Appellant’s second claim of ineffective assistance of counsel. View "Carter v. State" on Justia Law