Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of sexual battery. On appeal, Defendant argued, among other things, that the trial court erred when it granted the State’s request for a special jury instruction informing the jury that a sexual battery victim’s testimony need not be corroborated. The court of appeal affirmed, concluding that the trial court erred in giving the instruction but that the error was harmless. The Supreme Court quashed the decision of the court of appeal and remanded for a new trial, holding (1) the statement of law that the testimony of the victim need not be corroborated is not a proper jury instruction; and (2) the error in giving the instruction was not harmless in this case. View "Gutierrez v. State" on Justia Law

Defendant was charged with a single violation of Fla. Stat. 847.0135(3)(b), which prohibits the use of a computer to solicit the consent of a parent or legal guardian of a child to engage in unlawful sexual conduct with the child, and a single violation of section 847.1035(4)(b), which prohibits traveling to meet a minor to engage in unlawful sexual conduct after using a computer to make a prohibited solicitation. The State relied upon the same conduct to charge both offenses. Defendant pleaded guilty. On appeal, the court of appeal vacated Defendant’s conviction and sentence of solicitation, concluding that Defendant’s convictions for solicitation and traveling after solicitation impermissibly placed him in double jeopardy because the Legislature had not explicitly stated its intent to allow separate convictions for these offenses based upon the same conduct and because solicitation is a lesser-included offense of traveling after solicitation. The Supreme Court approved the court of appeal’s decision, holding that Defendant’s dual convictions for solicitation and traveling after solicitation based upon the same conduct impermissibly placed him in double jeopardy. View "State v. Shelley" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, two counts of grand theft of a motor vehicle, home-invasion robbery, two counts of burglary, and escape. The trial court imposed a sentence of death for the murder. The Supreme Court affirmed the convictions and death sentence, holding, (1) the trial court did not err in denying Defendant’s motion to sever certain of the charges; (2) the trial court did not err in denying Defendant’s motion to suppress his post-arrest statement; (3) any references that were made to defendant’s incarceration at the time of his escape were not so prejudicial as to vitiate the entire trial; (4) the prosecutor did not commit misconduct during guilt-phase closing statements or penalty-phase closing arguments; (5) the sentencing order was proper; (6) Defendant’s constitutional challenge to Florida’s capital sentencing scheme was without merit under established Florida precedent; and (7) the death sentence was not disproportionate in this case. View "Fletcher v. State" on Justia Law

Defendant was convicted and sentenced to death for the murders of a correctional officer and an inmate. Defendant committed the murders while attempting to escape from prison where he was serving a life sentence for a prior murder. Defendant filed a motion for postconviction relief pursuant to Fla. R. Crim. p. 3.851. The postconviction court denied relief. Defendant appealed and simultaneously petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the postconviction court’s denial of relief and denied Defendant’s petition for a writ of habeas corpus, holding (1) Defendant did not receive ineffective assistance of trial counsel during either the guilt phase or the penalty phase; (2) the postonviction court did not err in summarily denying two of Defendant’s postconviction claims; and (3) appellate counsel did not provide ineffective assistance. View "Eaglin v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder, armed robbery, armed burglary of a conveyance, and possession of a firearm by a convicted felon. Appellant was sentenced to death. The conviction and sentence were affirmed on direct appeal. Defendant later filed a motion under Fla. R. Crim. P. 3.851 to vacate his conviction of first-degree murder and sentence of death. After an evidentiary hearing on certain of the claims raised in the motion, the circuit court denied postconviction relief. Appellant filed a notice of appeal and then filed a petition for writ of habeas corpus, contending that his appellate counsel had provided ineffective assistance. The Supreme Court affirmed the order of the circuit court denying postconviction relief and denied the petition for writ of habeas corpus, holding that none of Appellant’s claims warranted relief. View "Hayward v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, robbery, and kidnapping. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s conviction and sentence on appeal. The instant motion was Defendant’s second successive postconviction motion. In it, Defendant asserted that he must be resentenced to life based on the newly discovered evidence that his codefendant, who was convicted for first degree murder, armed robbery, and armed kidnapping and originally received a death sentence, subsequently received a life sentence. The postconviction court denied relief. The Supreme Court affirmed, holding that Defendant failed to show that his codefendant’s sentence would probably result in a life sentence for Defendant on retrial. View "Hartley v. State" on Justia Law

Appellant was convicted of first-degree murder. The evidence presented at trial connecting Appellant to the murder consisted only of proof that his DNA was detected within scrapings collected from the victim’s left fingernails. Following the penalty phase and a Spencer hearing, the trial court imposed a sentence of death. The Supreme Court reversed and vacated Appellant’s conviction and sentence, holding that the record lacked competent, substantial evidence to sustain the conviction and that the State’s evidence was susceptible to the theory that, after Appellant made contact with the victim, the perpetrator killed her but left no detectable evidence at the crime scene. Remanded with directions that a judgment of acquittal be entered. View "Hodgkins v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder. The trial court sentenced Appellant to death. The Supreme court affirmed Appellant’s conviction and sentence of death. Appellant later filed an amended motion to vacate judgment of conviction and sentences pursuant to Fla. R. Crim. P. 3.851. After an evidentiary hearing, the circuit court denied the postconviction motion. The Supreme Court affirmed, holding (1) Appellant was not denied the effective assistance of trial counsel; and (2) Appellant failed to establish that that he was denied access to records that related to a colorable claim. View "Twilegar v. State" on Justia Law

After a retrial, Defendant was convicted of two counts of first-degree murder. The trial court sentenced Defendant to death for both murders. The Supreme Court affirmed the convictions and sentences on direct appeal. Defendant subsequently filed a seven-claim motion to vacate judgment of conditions and sentences and later amended his motion to add two additional claims. After an evidentiary hearing on some of the claims, the postconviction court denied all of Defendant’s claims. The Supreme Court affirmed the denial of postconviction relief and also denied Defendant’s petition for habeas corpus relief, holding (1) the postconviction court properly denied Defendant’s claims of ineffective assistance of counsel; (2) the postconviction court did not err in denying Defendant’s claim of newly discovered evidence; (3) Defendant waived his Brady claim; and (4) Defendant’s appellate counsel did not perform ineffectively. View "Brooks v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder. Appellant was sentenced to life in prison without the possibility of parole for one murder and to death for the second murder. The Supreme Court affirmed Appellant’s convictions and sentences, holding (1) the evidence was sufficient to support both of Appellant’s first-degree murder convictions; (2) the trial court did not err in its findings with respect to aggravating and mitigating circumstances; (3) the death penalty was proportionate in this case; and (4) Appellant’s claim that his death sentence was unconstitutional based on Ring v. Arizona was without merit under established Florida precedent. View "Hobart v. State" on Justia Law