Justia Florida Supreme Court Opinion Summaries

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

Petitioner was convicted of second-degree murder. In a previous habeas corpus proceeding, Petitioner sought release from incarceration, arguing that the assistant state attorney who signed the information and indictment in his criminal case was not authorized to sign informations and indictments because he did not have an oath on file. The court of appeal denied the petition as time-barred and meritless. Petitioner subsequently filed a petition for writ of mandamus in the Supreme Court asking the Court to compel the court of appeal to carry out its “legal ministerial duty” to grant him habeas corpus relief. The Supreme Court dismissed the petition as an unauthorized use of the writ of mandamus, as mandamus is not the proper vehicle to seek review of an allegedly erroneous decision by a lower court.View "Mathews v. Crews" on Justia Law

Petitioner filed a petition to invoke the First District Court of Appeal’s all writs jurisdiction, asserting that he was serving an illegally enhanced sentence. The First District dismissed the petition in an unelaborated per curiam decision. Petitioner sought review, alleging that the First District’s decision expressly and directly conflicted with several other district court decisions regarding illegal sentences. The Supreme Court dismissed Petitioner’s petition for review, holding that the Court “lacks discretionary review jurisdiction to review an unelaborated per curiam dismissal from a district court of appeal that is issued without opinion or explanation or that merely cites to a case not pending review in, or reversed or quashed by, the Court, or to a statute or rule of procedure.”View "Wells v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder under the felony murder and premeditated theories in the deaths of Berthum Gibson and Keenethia Keenan and guilty of first-degree murder under the felony murder theory in the death of Desmond Robinson. Defendant was sentenced to death for the deaths of Gibson and Keenan. The Supreme Court affirmed the convictions and sentences, holding (1) the evidence was sufficient to support Defendant’s convictions under both the felony murder and premeditation theories; (2) the trial court did not err in giving additional weight to the felony murder aggravating circumstance; (3) Defendant’s death sentences were proportional; and (4) Defendant’s death sentences were not unconstitutional under Ring v. Arizona.View "Smith v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed on direct appeal. Defendant subsequently filed an amended motion to vacate his judgment and sentence, which the postconviction court denied. Defendant appealed and filed an accompanying petition for writ of habeas corpus. The Supreme Court affirmed, holding (1) the postconviction court did not err in finding Defendant competent to proceed in his postconviction proceedings; (2) the postconviction court did not err in denying Defendant’s claim of ineffective assistance of trial counsel during the penalty phase and voir dire; (3) the postconviction court did not err in summarily denying Defendant’s claim that trial counsel was ineffective for failing to file a motion for a change of venue; (4) Florida’s method of execution for lethal injection is constitutional; and (5) Defendant was not entitled to relief on his claim that his right against cruel and unusual punishment would be violated because he may be incompetent at the time of execution.View "Franklin v. State" on Justia Law