Justia Florida Supreme Court Opinion Summaries

The Supreme Court quashed the decision of the Fifth District Court of Appeal to grant a writ of certiorari in this case, holding that the district court did not have certiorari jurisdiction.Defendant was charged with two offenses, after which the State obtained a search warrant to search Defendant's smartphone, which was passcode protected. The trial court granted the State's motion to compel Defendant to disclose the smartphone's passcode, overruling Defendan't objection that such compelled disclosure would violate his privilege against self-incrimination under the Fifth Amendment. The Fifth District granted Defendant's petition for a writ of certiorari contesting the order to compel. The Supreme Court quashed the decision below, holding that because the order before the district court did not cause Defendant irreparable harm the district court did not have certiorari jurisdiction. View "State v. Garcia" on Justia Law

The Supreme Court approved of the decision of the First District Court of Appeal affirming Defendant's conviction for sexual battery in violation of Fla. Stat. 794.011(5)(b), holding that subsection 5(b) is not facially unconstitutional because it does not remove the State's burden to prove the defendant's general intent to engage in the act that constitutes the offense under the statute.On appeal, Defendant argued that subsection 5(b) was facially unconstitutional or must be read to include a requirement that the State prove that a criminal defendant knew or should have known the victim did not consent to sexual intercourse. The First District affirmed, disagreeing with Defendant that section 794.011(5)(b) was unconstitutional because it does not require the State to prove a defendant's mens rea. The Supreme Court affirmed, holding that the Legislature's reach did not approach the extent of its constitutional grasp where the statute makes sexual battery a crime of general intent not a strict liability offense. View "Statler v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Quentin Marcus Truehill's postconviction motion filed pursuant to Fla. R. Crim. P. 3.851 and denied Truehill's petition for a writ of habeas corpus, holding that Truehill was not entitled to relief.After a jury trial, Truehill was found guilty of first-degree murder and kidnapping. The jury unanimously recommended that true hill be sentenced to death. Truehill timely filed a motion for postconviction relief, which the circuit court denied in its entirety. Truehill appealed and filed a petition for habeas relief. The Supreme Court denied relief, holding (1) the postconviction court did not err in denying Truehill's postconviction claims; and (2) neither of the claims raised in Truehill's petition for a writ of habeas corpus had merit. View "Truehill v. State" on Justia Law

The Supreme Court held that John F. Mosley, who was resentenced to death for the murder of his ten-month-old son after a second penalty phase trial, was entitled to a new Spencer hearing and sentencing hearing but was not entitled to a new trial.Mosley was convicted of two counts of first-degree murder and was sentenced to death. When Mosley sought postconviction relief, the Supreme Court decided that a new penalty phase was required under Hurst v. Florida, 577 U.S. 466 (2016). After a second penalty phase trial, the jury found that the aggravating factors were sufficient to impose the death penalty. Mosley filed a motion for a new penalty phase trial. Before the ensuing Spencer hearing, Mosley filed a motion to represent himself pro se. The trial court failed to address Mosley's motion and appointed a public defender as Mosley's appellate counsel. The Supreme Court vacated Mosley's death sentence and remanded for a new sentencing hearing, holding that the trial court abused its discretion by failing to address Mosley's motion to represent himself at his Spencer hearing. View "Mosley v. State" on Justia Law

The Supreme Court quashed the decision of the court of appeal determining that Appellant's motion for disqualification was legally sufficient but that the trial judge's failure to grant the motion did not require reversal of Appellant's judgments and sentences, holding that there was a reasonable possibility that the trial judge's failure to grant the motion to disqualify contributed to Appellant's conviction.At issue before the Supreme Court was what harmless error test, if any, an appellate court should apply when a defendant in a criminal case asserts in an appeal from a judgment and sentence that the trial court erred in denying his legally sufficient motion to disqualify the trial judge for alleged bias or prejudice. The Supreme Court held (1) the proper test is set forth in State v. DiGuilio, 491 So. 2d 1129 (Fla. 1986); and (2) the court of appeal in this case correctly applied the harmless error standard, but applying the test laid out in DiGuilio, it could not be said that there was no reasonable probability that the error affected the verdict. View "Davis v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions and sentences of death for the first-degree murders of Patricia Moran and Deborah Royal, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant raised several issues, two of which the Supreme Court decided merited individualized attention. The Court then affirmed, holding (1) Defendant's argument that the State was impermissibly motivated by race when it struck venireperson Kimberly James from the jury and that its proffered reasons for the strike were pretextual was improperly preserved; (2) competent, substantial evidence supported the jury's verdict finding Defendant guilty of two counts of attempted first-degree murder with a vehicle; and (3) Defendant's remaining allegations of error were without merit. View "Gordon v. State" on Justia Law

The Supreme Court reversed the judgment of the postconviction court partially granting Defendant's motion to vacate his first-degree murder convictions and sentences of death pursuant to Fla. R. Crim. P. 3.851, holding that the postconviction court erred in granting a new penalty phase.Defendant pleaded guilty to two counts of first-degree murder and one count of attempted first-degree murder. After waiving a penalty-phase jury, Defendant was sentenced to death. Defendant later filed a postconviction motion under Fla. R. Crim. P. 3.851. The postconviction court summarily denied Defendant's four purely legal claims but granted a new penalty phase, ruling that counsel was deficient in investigating and presenting mitigating evidence, which prejudiced Defendant. The Supreme Court reversed, holding that Defendant failed to establish deficient performance in any respect. View "State v. Mullens" on Justia Law

The Supreme Court held that a completed purchase of illegal drugs necessarily entails the defendant purchaser's possession of those drugs, as federal law defines possession, and a purchase is not necessarily complete as soon as the would-be purchaser pays for the drugs.Defendant was convicted of a gun possession crime and sentenced to a mandatory prison term under the Armed Career Criminal Act (ACCA) after the trial court concluded that Defendant had three previous convictions for a "serious drug offense" as defined by the ACCA. At issue was whether one of Defendant's previous drug trafficking offenses met the ACCA's definition of a "serious drug offense." On appeal, Defendant argued that a purchase is complete upon payment by the defendant, and therefore, a completed purchase does not require proof that Defendant possessed the purchased drugs. The Eleventh Circuit Court of Appeal certified the question to the Supreme Court. The Court answered that, for purposes of Fla. Stat. 893.135(1), a completed purchase requires proof that Defendant both gave consideration for and obtained control of a trafficking quantity of illegal drugs. View "Conage v. United States" on Justia Law

The Supreme Court affirmed the decision of the postconviction court denying Defendant's motion to vacate his convictions and sentences, including three convictions for first-degree murder and three sentences of death, holding that Defendant was entitled to neither postconviction relief nor a writ of habeas corpus.In 2014, Defendant pleaded guilty to murdering his girlfriend and her two children. The trial court sentenced Defendant to death for each murder. Defendant later filed a motion for postconviction relief, which the trial court denied. Defendant appealed the court's decision and filed a petition for a writ of habeas corpus, raising two claims. The Supreme Court denied relief, holding (1) as to Defendant's petition for postconviction relief, Defendant failed to demonstrate error, deficiency, or prejudice as to any of his claims; and (2) as to Defendant's habeas corpus petition, Defendant was not entitled to relief on his claims. View "Covington v. State" on Justia Law

The Supreme Court quashed the decision of the Fourth District Court of Appeal affirming Defendant's conviction for arson but finding that his due process rights were violated during sentencing and remanding for resentencing, holding that the trial court committed no fundamental error.After a second trial, Defendant was convicted of arson. The sentencing court conducted the analysis required in Banks v. State, 732 So. 2d 1065 (Fla. 1999) and declared to depart from the minimum sentence, as requested by Defendant. The Fourth District affirmed in part and reversed in part, holding that the trial court committed fundamental error when it considered impermissible sentencing factors. The Supreme Court quashed the decision below, holding that the trial court's determination that a sentence of eighty-four months was appropriate did not reflect the court's having committed fundamental error on the order of an illegal sentence. View "State v. Garcia" on Justia Law