Justia Florida Supreme Court Opinion Summaries

After a jury trial, Appellant was sentenced to death for the murders of four individuals. The Supreme Court affirmed Appellant’s convictions and sentences. Appellant subsequently filed a motion for postconviction relief. The postconviction court denied relief after summarily denying several claims and holding an evidentiary hearing on Appellant’s claims of ineffective assistance of counsel. Appellant appealed the denial of his postconviction motion and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of Appellant’s postconviction motion and denied his habeas petition, holding (1) the trial court did not err in denying Appellant’s claims that trial counsel were ineffective during the guilt phase and the penalty phase; and (2) Appellant was not entitled to relief on his argument that Florida’s death penalty statute violates the Eighth Amendment’s standards of decency. View "Hunter v. State" on Justia Law

After a jury trial, Defendant was convicted of, among other crimes, first-degree felony murder for the murder of a police officer. Defendant was sentenced to death for the murder. Defendant raised three issues on appeal, his primary argument being that his death sentence was disproportionate. The Supreme Court affirmed the convictions but reversed Defendant’s sentence of death, holding that the death penalty was disproportionate under the facts presented here, as this was not one of the most aggravated and least mitigated of capital murders. Remanded to the trial court with directions to impose a life sentence. View "Delgado v. State" on Justia Law

After a jury trial, Defendant was found guilty of second-degree murder, among other offenses. Defendant was received a sentence of life imprisonment for the murder conviction. On appeal, Defendant argued that the trial court erred by refusing to allow defense witness Angela Tyler to testify about Ray Allen Brown’s out-of-court statement and in prohibiting Defendant from questioning Brown about the purported statements he made to Tyler. The district court affirmed. Defendant appealed, arguing, inter alia, that the trial court erred (1) when it infringed upon the jury’s role by determining that Tyler's testimony was not credible, and (2) in evaluating the corroboration factor of the Chambers v. Mississippi analysis because it rejected Defendant’s own statement to detectives as adequate corroboration of Brown’s alleged confession. The Supreme Court quashed the district court’s decision, holding (1) the trial court improperly evaluated the credibility of Tyler’s testimony and erred when it excluded her testimony on that basis; and (2) a defendant’s own statement may be considered as corroboration of a witness’ testimony for the purpose of the corroboration factor of the Chambers analysis. View "Bearden v. State" on Justia Law

Defendant was indicted on charges of first-degree murder and robbery with a weapon and pled guilty to both counts. At the conclusion of the penalty phase, the jury returned a unanimous recommendation of death. The trial court sentenced Defendant to death. The Supreme Court affirmed the convictions and sentences. Defendant later filed a motion to vacate the judgment of conviction under Fla. R. Crim. P. 3.851, alleging that he had received ineffective assistance of counsel. The postconviction court denied relief. The Supreme Court affirmed, holding that Defendant failed to demonstrate ineffective assistance of counsel as to any of his claims. View "Guardado v. State" on Justia Law

In this case, the Third District Court of Appeal read Graham v. Florida as creating a homicide-case exception to the categorical rule against sentencing a juvenile offender to life without parole for a nonhomicide crime. The court’s reading would permit a juvenile to be sentenced to life without parole for a nonhomicide offense if the juvenile also committed a homicide in the same criminal episode. Applying this homicide-case exception, the Third District held that Defendant’s life-without-parole sentences for certain nonhomicide offenses committed as a juvenile were constitutional under Graham because Defendant also committed a homicide in the same criminal episode. The Supreme Court quashed the Third District’s decision, holding that Graham’s categorical rule leaves no room for the homicide-case exception recognized by the state’s Second, Third, and Fourth District Courts of Appeal. Remanded with instructions that Lawton be resentenced for the nonhomicide offenses of attempted first-degree murder with a firearm and armed robbery with a firearm. View "Lawton v. State" on Justia Law

Defendant was fifteen years old when she took part in an attempted robbery that resulted in a death. Defendant was convicted of first-degree murder, among other crimes. The trial court imposed a mandatory sentence of life imprisonment without the possibility of parole for the murder. A decade after Defendant’s convictions and sentences became final, the U.S. Supreme Court issued its decision in Miller v. Alabama. Defendant subsequently filed a motion for postconviction relief and to correct an illegal sentence, asserting that her sentence was unconstitutional under Miller and, therefore, she was entitled to be resentenced. The trial court denied the motion on the basis of the First District Court of Appeal’s precedent in Gonzales v. State, which held that Miller did not apply retroactively. The First District affirmed. The Supreme Court reversed, holding (1) the Supreme Court’s decision in Miller applies retroactively to juvenile offenders whose convictions and sentences were final at the time Miller was decided; and (2) based on the Court’s decision in Horsley v. State, the appropriate remedy for any juvenile offender whose sentence is now unconstitutional under Miller is to conduct a resentencing proceeding consistent with the provisions of chapter 2014-220, Laws of Florida. View "Falcon v. State" on Justia Law

Defendant was seventeen years old when he participated in the robbery of a convenience store, during which an owner was killed. The jury convicted Defendant of first-degree murder, among other charges. Defendant was sentenced to life imprisonment without the possibility of parole for the murder. While Defendant’s appeal was pending, the U.S. Supreme Court decided Miller v. Alabama. Defendant subsequently filed a motion to correct his sentence, asserting that he was entitled to be resentenced with individualized consideration based on Miller. The trial court agreed with Defendant but concluded that it did not have the discretion to consider a term of years as a sentencing option. Thereafter, the court again sentenced Defendant to life imprisonment without the possibility of parole. The Fifth District Court of Appeal vacated Defendant’s sentence, concluding that the only sentence now available in Florida for a charge of capital murder committed by a juvenile was life with the possibility of parole after twenty-five years. The Supreme Court quashed the underlying decision and remanded the case for resentencing, holding that the proper remedy is to apply chapter 2014-220, Laws of Florida, to all juvenile offenders whose sentences are unconstitutional under Miller. View "Horsley v. State" on Justia Law

When he was seventeen years old, Defendant was tried as an adult and convicted of, among other nonhomicide offenses, three counts of sexual battery while possessing a weapon, two counts of robbery, and one count of kidnapping. After Defendant was initially sentenced to life imprisonment plus sixty years, in light of the recently issued Graham v. Florida decision, the trial court resentenced Defendant to concurrent thirty-year sentences for the sexual batteries. The remaining sentences were to run consecutively. The Fifth District Court of Appeal affirmed, holding that Graham does not apply to term-of-years prison sentences because such sentences do not constitute life imprisonment. The Supreme Court quashed the decision below and remanded for resentencing, holding (1) the constitutional prohibition against cruel and unusual punishment under Graham is implicated when a juvenile nonhomicide offender’s sentence does not afford any meaningful opportunity to obtain release based on demonstrated maturity and reform; and (2) because Defendant’s aggregate sentence did not afford him this opportunity, his sentence was unconstitutional under Graham. View "Henry v. State" on Justia Law

When Defendant was fourteen years old he pleaded guilty to attempted first-degree murder, attempted armed robbery, and aggravated battery. The trial court adjudicated Defendant guilty as charged and imposed prison terms of seventy years for the attempted murder conviction and twenty-five years for the attempted armed robbery conviction. Defendant appealed and filed a motion pursuant to Fla. R. Crim. P. 3.800(b)(2), arguing that, under the rationale of Graham v. Florida, his seventy-year prison sentence constituted cruel and unusual punishment. The trial court denied the requested relief. The First District Court of Appeal affirmed, holding that Graham did not apply in Defendant’s case because he did not face a life sentence without the possibility of parole. The Supreme Court quashed the First District’s decision to the extent it affirmed the seventy-year prison sentence and remanded to Defendant’s sentencing court, holding that Defendant’s seventy-year prison sentence did not provide a meaningful opportunity for future release, and therefore, the sentence was unconstitutional in light of Graham. View "Gridine v. State" on Justia Law

After a jury trial, Defendant was convicted of second-degree murder and sentenced to forty-five years in prison. Defendant appealed, arguing that the trial judge erred in instructing the jury on the lesser included offense of manslaughter to require that to convict for that lesser offense the jury must find that Defendant intended to cause the death of the victim. The Court of Appeal agreed that the jury instruction on manslaughter was erroneous but rejected the claim of fundamental error because Defendant’s sole defense was misidentification, and therefore, Defendant failed to place any of the other elements of the offense in dispute, including the element of intent. The Supreme Court quashed the decision of the Court of Appeal, holding that fundamental error occurred that required a new trial where, because Defendant did not concede the intent by which the homicide was committed, proof on that issue remaining on the State and remained in dispute notwithstanding Defendant’s defense of misidentification. View "Griffin v. State" on Justia Law