Justia Florida Supreme Court Opinion Summaries

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

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