Justia Florida Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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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

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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

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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

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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

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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

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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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