Justia Florida Supreme Court Opinion Summaries

In Sirota v. State, the court of appeal certified a question to the Supreme Court regarding the scope and proper application of the Court’s decision in Morgan v. State. Thereafter, the Supreme Court decided Alcorn v. State, wherein the Court receded from Morgan with respect to the standard for establishing prejudice as to ineffective assistance of counsel claims in which the defendant rejected a plea offer based on misadvice. After Alcorn became final, the Court issued an order directing the defendant below to show cause why the Court should not summarily quash the court of appeal’s decision in Sirota and remand for reconsideration in light of Alcorn. After the parties responded, the Supreme Court quashed the court of appeal’s decision in Sirota and remanded for further proceedings consistent with the Court’s decision in Alcorn. View "State v. Sirota" on Justia Law

Appellant was convicted and sentenced to death for the first-degree murder of Monquell Wimberly. Appellant was also convicted of the first-degree felony murder of Patrick Stafford, for which Stafford was sentenced to life imprisonment. The Supreme Court affirmed Appellant’s convictions and sentence of death, holding (1) there was no fundamental error in the admission of a videotaped statement Appellant gave to detectives after he was taken into custody; (2) there was no prejudicial error in the admission of a codefendant’s out-of-court statement; (3) the admission of testimony concerning an eyewitness’s fear of the shoot did not constitute fundamental error; (4) Appellant was not entitled to relief on his claim of juror misconduct or premature deliberation; and (5) competent, substantial evidence supported the verdict of guilt as to the first-degree murder conviction and the felony murder conviction. View "Sheppard v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder and one count of armed carjacking. The trial court sentenced Appellant to death. The Supreme Court affirmed Appellant’s convictions and sentences on appeal. Appellant subsequently filed a motion for postconviction relief, raising twenty-eight claims. After an evidentiary hearing on several of those claims, the circuit court denied relief. Appellant appealed, raising twenty-one claims, and also filed a habeas petition raising two claims of ineffective assistance of appellate counsel. The Supreme Court (1) affirmed the postconviction court’s order denying relief on all postconviction claims, holding that Appellant failed to establish that any errors occurred which, either individually or cumulatively, would entitle him to a new trial; and (2) denied relief on both claims Appellant raised in his petition for writ of habeas corpus, as both claims were procedurally barred. View "Deparvine v. State" on Justia Law

Appellant was convicted of first-degree murder in the shooting death of a law enforcement officer, which occurred after the officer stopped Appellant for a traffic infraction. The jury recommended that the death penalty be imposed, and the circuit court sentenced Appellant to death. Appellant filed an amended motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, alleging that his trial counsel provided ineffective assistance. The court below denied the motion in a final order. The Supreme Court affirmed, holding that Appellant failed to satisfy the Washington v. Strickland standard in the postconviction proceeding held below. View "Bailey v. State" on Justia Law

Appellant was convicted of first-degree murder and sentenced to death for killing a Florida Highway Patrol Trooper. The Governor set a death warrant for Appellant and scheduled his execution for February 26, 2014. This appeal concerned the denial of Appellant’s amended third successive motion for postconviction relief in which he challenged the Florida lethal injection protocol as applied to him. The Supreme Court affirmed the postconviction court’s denial of relief, holding (1) Appellant's suggestion that the Court depart from its established precedent as to the proper standard to apply to an Eighth Amendment challenge to the lethal injection protocol was unavailing; (2) the use of midazolam hydrochloride in the 2013 lethal injection protocol does not violate the Eighth Amendment; (3) the forced administration of vecuronium bromide does not violate Appellant’s Fourteenth Amendment rights under Sell v. United States because the holding of Sell does not apply to these circumstances; and (4) the postconviction court did not err in denying Appellant’s request to strike a witness’s testimony.View "Howell v. State " on Justia Law

S.A. filed a notice of expiration of speedy trial and a motion seeking a discharge under the speedy trial rule, alleging that he was entitled to a discharge because the State failed to bring him to trial within the fifteen-day recapture window. The State argued that it had brought S.A. to trial within the recapture window because (1) the recapture window consists of two separate five- and ten-day periods calculated pursuant to the computation of time rule; and (2) the hearing on S.A.’s motion was held within five days of the date S.A. filed his motion, and S.A. was brought to trial within ten days of the hearing. The trial court discharged S.A. The court of appeal affirmed, holding that the recapture window is one fifteen-day time period. The Supreme Court quashed the decision of the court of appeals, holding (1) the recapture window is calculated as two separate five- and ten-day time periods; and (2) therefore, S.A. was not entitled to a discharge. View "State v. S.A." on Justia Law

After a jury trial, Appellant was convicted of the first-degree murder, kidnapping, and sexual battery of a nine-year-old and sentenced to death. After the Governor signed the warrant in this case Appellant filed numerous public records requests, a second successive motion for postconviction relief, and a request for a stay of execution. The circuit court denied Appellant's public records requests, his postconviction petition, and his request for a stay of execution. The Supreme Court affirmed in all respects, holding that the circuit court did not err in its rulings. View "Chavez v. State" on Justia Law

After a second jury trial, Appellant was convicted of first-degree murder and robbery and was sentenced to death. The Supreme Court affirmed the convictions but twice remanded for new penalty phases. Each time, the trial court sentenced Defendant to death. The Supreme Court affirmed the sentence of death. Appellant subsequently moved to vacate judgment of convictions and sentences, alleging ineffective assistance of counsel. The postconviction court denied all claims presented in Appellant’s motion to vacate. The Supreme Court affirmed, holding that the postconviction court did not err in denying Appellant’s claims of ineffective assistance of counsel during his second guilt phase trial and during his fourth penalty phase trial.View "Lebron v. State" on Justia Law

Petitioner was convicted and sentenced to thirty years imprisonment for robbery. The court of appeal affirmed the judgment of guilty and the sentence imposed. Thereafter, Petitioner filed numerous postconviction claims. The petition filed in this case was Petitioner’s twenty-seventh petition for review or extraordinary writ petition filed in the Supreme Court pertaining to his criminal case. The petition was one for a writ of habeas corpus. The Court dismissed the petition as unauthorized pursuant to Baker v. State and issued an order directing Petitioner to show cause why he should not be prohibited from filing any further pro se filings in the Court related to his criminal case. Petitioner did not file a response but instead filed several handwritten “motions” asserting the same challenges to his conviction and sentence that he presented in other filings. The Supreme Court denied the motions, concluded that Petitioner’s petition was procedurally barred as well as a frivolous proceeding, and imposed sanctions upon Petitioner. View "Lockhart v. Crews" on Justia Law

After Respondent violated his conditional release, the parole examiner recommended that Respondent be restored to regular supervision. The Florida Parole Commission (FPC) rejected the parole examiner’s recommendation and revoked Respondent’s conditional release. Respondents subsequently filed a pro se petition for a writ of habeas corpus, which the circuit court denied. Respondent then filed a pro se petition for a writ of certiorari, arguing that the FPC failed to follow Florida’s Administrative Procedures Act by rejecting the parole examiner’s recommendation. The district court granted the petition. The FPC petitioned the Supreme Court for review on the basis that the district court’s decision expressly and directly conflicted with Sheley v. Florida Parole Commission. The Supreme Court quashed the district court’s decision, holding (1) the district court’s decision exceeded the scope of second-tier certiorari review; and (2) the district court erred in granting certiorari relief because the circuit court’s decision did not result in a miscarriage of justice.View "Fla. Parole Comm’n v. Taylor" on Justia Law