Justia Florida Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant’s convictions and sentences on appeal. Defendant later filed a motion for postconviction relief, raising twenty-nine claims. The circuit court denied each of Defendant’s claims. Defendant appealed the denial of five claims and filed a petition for a writ of habeas corpus, raising two additional claims. The Supreme Court affirmed the postconviction court’s denial of Defendant’s claims and denied Defendant’s petition for a writ of habeas corpus, holding (1) the postconviction court properly denied Defendant’s claims of Brady violations, ineffective assistance of trial counsel, improper juror communication, and cumulative error; and (2) Appellant was not entitled to habeas relief based on alleged ineffective assistance of appellate counsel. View "Whitton v. State" on Justia Law

Defendant was charged with one count each of grand theft and dealing in stolen property. Defendant executed a plea of guilty or no contest as to both offenses, and the trial court adjudicated Defendant of both offenses. Defendant appealed, arguing that the trial court violated Fla. Stat. 812.025 by adjudicating her guilty of both theft and dealing in stolen property. The Second District agreed with Defendant and reversed, holding that the trial court erred in adjudicating Defendant guilty of both offenses. The district court remanded with directions that the trial court vacate the grand theft conviction, the lesser offense, and to resentence Defendant accordingly. The Supreme Court quashed the district court’s decision, holding that the proper remedy on appeal in this case was to remand the case for the trial court to exercise its discretion in vacating the adjudication of guilt of either the dealing in stolen property or theft count and to resentence Defendant on the remaining count. View "Anucinski v. State" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant’s conviction and sentence, holding (1) the trial court properly considered in mitigation Defendant’s IQ score in conjunction with evidence of his low cognitive functioning; (2) Defendant was not entitled to relief on his claim that the trial court failed to consider, find, and weigh as a mitigating circumstance that Defendant had a history of drug and alcohol abuse; (3) trial court did not err in finding as aggravating circumstances that the homicide was committed in a cold, calculated, and premeditated manner and was especially heinous, atrocious, or cruel; (4) Defendant’s claim that Florida’s death penalty scheme is unconstitutional under Ring v. Arizona was without merit; (5) there was sufficient evidence to affirm Defendant’s conviction for first-degree murder; and (6) Defendant’s death sentence was proportional to other cases where the Court has upheld a sentence of death. View "Martin v. State" on Justia Law

Petitioner was convicted of four counts of armed sexual battery and ultimately sentenced to four life sentences as upward departure sentences. The second district affirmed Petitioner’s four life sentences. Petitioner later filed a motion to correct illegal sentence under Fla. R. Crim. P. 3.800(a), claiming that under Apprendi v. New Jersey and Blakely v. Washington he was entitled to a jury trial at his resentencing to determine the factual basis for the upward departure. The circuit court denied the motion, finding that Petitioner’s sentences were within their statutory maximums. The Second District affirmed, concluding that Petitioner’s claim of Apprendi error was not a ground for relief under rule 3.800(a) because it was not preserved and raised on direct appeal. The Supreme Court quashed the Second District’s decision and remanded to the district court for the application of a harmless error analysis, holding that Petitioner’s four life sentences were unconstitutionally enhanced under Apprendi and Blakely, and therefore, the sentences were illegal under rule 3.800(a). View "Plott v. State" on Justia Law

In 1989, Petitioner was sentenced to terms of incarceration for robbery and aggravated battery convictions. Neither of those sentences was imposed under the habitual offender statute. While incarcerated, Petitioner was convicted of inmate possession of contraband and sentenced under the habitual offender statute to a term of incarceration. The provisional release date for Petitioner reflected only the 410 days of provisional credits that he acquired prior to his sentence as a habitual offender. Petitioner challenged the Florida Department of Correction’s (DOC) award of provisional credits, claiming he was eligible for 1,080 days of provisional credits for the robbery and aggravated burglary sentences. The DOC responded that an inmate sentenced as a habitual offender was no longer eligible to receive provisional credits on non-habitual offender sentences. The First District denied Petitioner’s petition for writ of certiorari. The Supreme Court approved the First District’s decision, holding that Fla. Stat. 944.277 renders an inmate ineligible to receive provisional credits on any sentence after the inmate has received a habitual offender sentence, even where the habitual offender sentence is imposed subsequent to a sentence that is otherwise eligible for provisional credits. View "Leftwich v. Fla. Dep’t of Corr." on Justia Law

After a jury trial, Appellant was convicted of the kidnapping, capital sexual battery, and first-degree murder of an eleven-year-old girl. The trial court sentenced Appellant to death for the murder. The Supreme Court affirmed Appellant’s convictions and sentences on appeal. Appellant subsequently filed a motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, presenting several claims. The postconviction court summarily denied all claims. The Supreme Court affirmed, holding (1) Appellant’s argument that criminal defense counsel should have unlimited authority to conduct interviews to probe jurors for possible misconduct was without merit; (2) the postconviction court properly denied Appellant’s claims that the trial court improperly instructed the jury regarding its role; (3) the postconviction court did not err when it held that Florida’s capital sentencing statute is not unconstitutional; and (4) Appellant’s challenge to the constitutionality of Florida’s lethal injection procedures was without merit. View "Smith v. State" on Justia Law

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