Justia Florida Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Muhammad v. State
In 1980, Appellant was convicted of first-degree murder and sentenced to death. After the Governor signed the death warrant in this case, Appellant filed a successive motion for postconviction relief seeking to vacate his judgments of conviction and sentence of death. Appellant also filed motions for disclosure of public records, discovery, and for a stay. The circuit court summarily denied the motions and postconviction claims. The Supreme Court temporarily relinquished jurisdiction for the purpose of holding an evidentiary hearing on the sole issue of the safety and efficacy of the new drug in the lethal injection procedure. After an evidentiary hearing, the circuit court rejected the claim that the use of midazolam hydrochloride as the first drug in the three-drug lethal injection protocol would result in a substantial risk of serious harm and, accordingly, held that the protocol was constitutional. The Supreme Court (1) affirmed the circuit court's order denying postconviction relief on the claims raised in Appellant's successive postconviction motion; but (2) reversed the circuit court's order denying Appellant's public records request for copies of his own inmate and medical records and ordered transmission of copies of those records to Appellant's counsel.View "Muhammad v. State" on Justia Law
McCoy v. State
Defendant pled guilty to first-degree murder with a firearm. After a penalty-phase proceeding conducted before a jury, the trial court imposed the death sentence for the murder. The Supreme Court affirmed the conviction and sentence of death, holding (1) the trial court did not abuse its discretion in finding and assigning great weight to a cold, calculated, and premeditated (CCP) aggravator; (2) Defendant's death sentence was a proportionate punishment in this case; (3) Defendant failed to present any compelling reason for the Court to reconsider its established precedent on the issue of whether a mental illness rendered Defendant's execution unconstitutional; and (4) Defendant's guilty plea was knowingly, intelligently, and voluntarily entered. View "McCoy v. State" on Justia Law
Hildwin v. State
Appellant was convicted of first-degree murder and sentenced to death. In the guilt phase of Appellant’s trial, the State introduced a pair of women’s underwear and a white washcloth, both of which were found at the crime scene. The State presented evidence that showed that biological material contained on the items was consistent with having been left by Appellant. The Supreme Court vacated Appellant’s murder conviction and death sentence based on newly discovered DNA evidence that established that the victim’s boyfriend - not Appellant - was the provider of the biological material found on the crime scene evidence. Remanded for a new trial. View "Hildwin v. State" on Justia Law
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Criminal Law
Poole v. State
Appellant was convicted of first-degree murder, attempted first-degree murder, and related crimes. The jury recommended that Appellant be sentenced to death, and the judge followed the jury’s recommendation. On appeal, the Supreme Court vacated Appellant’s death sentence based on the cumulative effect of errors made during the penalty phase of the trial. Following a new penalty phase, the trial court again sentenced Appellant to death. The Supreme Court upheld the trial court’s imposition of the death penalty on resentencing, holding (1) the trial court did not abuse its discretion in allowing the State’s strikes of two African American venirepersons; (2) the trial court did not abuse its discretion in allowing the State to introduce the severed fingertip of one of the victims into the new penalty phase; (3) the prosecutor engaged in improper arguments, but the errors were harmless; and (4) the death sentence in this case was appropriate. View "Poole v. State" on Justia Law
Duckett v. State
Appellant murdered an eleven-year-old girl while on duty as a police officer. After a jury trial, Appellant was convicted of sexual battery and first-degree murder. The trial court sentenced Appellant to death after finding two aggravating factors. The Supreme Court affirmed Appellant’s convictions and sentences on appeal. This appeal concerned the circuit court’s order summarily denying Appellant’s successive motion for postconviction relief in which Appellant claimed, among other things, that newly discovered evidence demonstrated that an FBI analyst’s testimony at trial regarding hair evidence was erroneous. The Supreme Court affirmed, holding (1) because Appellant’s successive motion constituted relitigation of the same hair-analysis issues that Appellant previously raised, without success, he was not entitled to any relief; and (2) the postconviction court did not err in denying relief on Appellant’s remaining claims. View "Duckett v. State" on Justia Law
Peterson v. State
After a jury trial, Charles Peterson was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed the conviction and sentence. Peterson subsequently filed a postconviction motion in the circuit court, alleging ineffective assistance of counsel. The postconviction court denied relief. Peterson appealed the denial of his postconviction motion and also petitioned for a writ of habeas corpus, claiming that his appellate counsel provided ineffective assistance. The Supreme Court affirmed the postconviction court’s denial of relief and denied Peterson’s petition for a writ of habeas corpus, holding (1) Peterson’s claims that his trial counsel should have challenged certain jurors for cause and failed to effectively use peremptory challenges were without merit; (2) trial counsel was not ineffective for failing to challenge in- and out-of-court identifications; and (3) appellate counsel was deficient for providing incorrect information to the Court, but appellate counsel’s misstatement did not compromise the appellate process to such a degree as to undermine confidence in the correctness of the result. View "Peterson v. State" on Justia Law
State v. Chubbuck
Respondent pleaded guilty to drug-related offenses. After Respondent violated the conditions of his probation, the trial court revoked his probation and sentenced him to ninety-six days in jail with ninety-six days credit for time served. In so sentencing Respondent, the trial court imposed a downward sentence under Fla. Stat. 921.0026(2)(d), which authorizes a downward sentence if the “defendant requires specialized treatment for a mental disorder that is unrelated to substance abuse or addiction or for a physical disability, and the defendant is amenable to treatment.” The State appealed, arguing that because Respondent did not present evidence that the Department of Corrections (DOC) could not provide the specialized treatment, insufficient evidence supported the trial court’s decision to impose a downward departure sentence. The district court disagreed with the State. The Supreme Court affirmed, holding that the plain language of the statute does not require the defendant to prove that the specialized treatment is unavailable in the DOC. View "State v. Chubbuck" on Justia Law
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Criminal Law
Henry v. State
After a retrial, Appellant was convicted of the first-degree murder of his second wife. After an unsuccessful appeal and the denials of Appellant’s petitions for postconviction and habeas relief, the Governor signed a death warrant for Appellant and scheduled an execution date. Postconviction counsel subsequently requested a competency hearing under Fla. Stat. 922.07. Three experts reported after an examination that Appellant did not suffer from a psychiatric illness or intellectual disability and understood that nature of the death penalty and why the sentence had been imposed on him. Thereafter, Appellant filed a motion for determination of intellectual disability as a bar to execution, which the circuit court dismissed as untimely. The Supreme Court affirmed the postconviction court’s order dismissing Appellant’s motion, holding that Appellant did not demonstrate a facially sufficient claim of intellectual disability. View "Henry v. State" on Justia Law
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Criminal Law
McLean v. State
Appellant was convicted of first-degree murder and sentenced to death. Appellant’s conviction and death sentence were affirmed on direct appeal. Appellant subsequently filed a motion for postconviction relief, asserting eleven claims. The circuit court denied relief on all of Appellant’s claims. Appellant appealed and filed a petition for a writ of habeas corpus. The Supreme Court affirmed the denial of Appellant’s motion for postconviction relief and denied his habeas petition, holding (1) Appellant’s trial counsel did not provide ineffective assistance during the guilt phase or penalty phases of trial; (2) Appellant’s due process rights were not violated by the State’s institutional policy of reprocessing tape recordings of tips received by Crimeline, a crime reporting hotline, including a recording of a tip that implicated him in the crime of which he was charged; and (3) Appellant’s challenges to Florida’s capital sentencing scheme were without merit. View "McLean v. State" on Justia Law
Moore v. State
Defendant was convicted of robbing and killing Johnny Parrish and burning down Parrish's house. The trial court sentenced Defendant to death for the first-degree murder conviction. Defendant subsequently filed two postconviction motions and two additional petitions for a writ of habeas corpus, all of which were denied. Defendant then instituted this second successive postconviction motion, raising three claims. After an evidentiary hearing, the postconviction court denied relief. The Supreme Court affirmed, holding (1) Defendant failed to meet his burden to demonstrate that the State knowingly presented false or misleading evidence that it failed to correct at Defendant's trial in violation of Giglio v. United States; and (2) Defendant failed to show that newly discovered evidence was of "such a nature that it would probably produce an acquittal on retrial."View "Moore v. State" on Justia Law