Justia Florida Supreme Court Opinion Summaries

In 2002, Petitioner was convicted of first-degree murder and sentenced to life imprisonment. Following his unsuccessful appeal, Petitioner filed numerous postconviction claims and extraordinary writs, all without success. This case involved Petitioner’s tenth petition for an extraordinary writ pertaining to his criminal case. The Supreme Court 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 and why the Court should not determine that the petition filed here was frivolous and subject to disciplinary procedures. The Court ultimately concluded that sanctions should be imposed and that Petitioner’s petition was a frivolous proceeding. View "Bush v. Crews" on Justia Law

Defendant was convicted of the 1985 first-degree murder of his wife. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s conviction and sentence. After Defendant’s postconviction motion and petition for writ of habeas corpus were denied, the Governor signed a death warrant for Defendant setting execution for June 18, 2014. Defendant filed a motion for determination of intellectual disability as a bar to execution, which the circuit court dismissed. The Supreme Court affirmed, holding that Defendant did not demonstrate a facially sufficient claim of intellectual disability and that no motion for rehearing would be entertained by the Court. View "Henry v. State" on Justia Law

Adrien Mobley was murdered in 1987, and for fifteen years, the case languished. DNA testing finally led investigators to Defendant. After a jury trial in 2011, Defendant was convicted of the murder and aggravated battery of Mobley and was sentenced to death for the murder conviction. The Supreme Court reversed and vacated both of Defendant’s convictions and sentences, holding that there was a lack of competent substantial evidence to conclude, beyond a reasonable doubt, that Defendant was the person responsible for Mobley’s death, as the competent substantial evidence linked Defendant to Mobley’s car, not Mobley’s murder. Remanded for a judgment of acquittal. View "Dausch v. State" on Justia Law

Petitioners, inmates under a sentence of death, challenged the facial validity of four provisions of the Timely Justice Act of 2013, which was enacted to “reduce delays in capital cases and to ensure that all appeals and postconviction actions in capital cases are resolved as soon as possible after the date a sentence of death is imposed in the circuit court.” The disputed portions of the Act were the provisions that governed conflict of interest and substitute counsel, constitutionally deficient representation, capital postconviction public records production, and the issuance of a warrant of execution. The Supreme Court denied the petition, holding that the challenged provisions of the Act did not facially violate the constitution. View "Abdool v. Bondi" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed the conviction and sentence on appeal. Appellant subsequently filed a postconviction motion seeking to vacate his conviction and sentence as well as a motion seeking a ruling that he was ineligible to be executed due to mental retardation. The postconviction court denied both motions. Appellant appealed the denial of his motions and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the postconviction court's orders and denied Appellant's habeas petition, holding (1) Appellant was not entitled to relief on any of his claims raised in his motion for postconviction relief; (2) Appellant was not entitled to relief on his mental retardation-related claims; and (3) Appellant's habeas claims were not properly presented in a petition for a writ of habeas corpus, and thus, Appellant was not entitled to habeas corpus relief. View "Diaz v. State" on Justia Law

After a jury trial in 1985, Appellant was convicted of first-degree murder and sexual battery. Appellant later filed a motion for postconviction relief seeking to have his convictions vacated after newly discovered evidence revealed that there was no seminal fluid found in the victim. At the time of Appellant's trial, the Florida law enforcement department tested vaginal and anal swabs of the victim and got a positive result for acid phosphatase (AP). The AP evidence was crucial to the State's case that a sexual battery occurred especially since the victim was found fully clothed and the medical examiner relied on the now-discredited testing that AP was present in order to conclude the victim was sexually battered. The newly discovered evidence also impacted the first-degree murder conviction because without evidence that a sexual battery occurred, the evidence linking Appellant to the murder was scant. The circuit court denied relief. The Supreme Court reversed and vacated Appellant's convictions and sentences, holding that the newly discovered evidence weakened the case against Appellant so as to give rise to a reasonable doubt as to his culpability. Remanded for a new trial.View "Swafford v. State" on Justia Law

After certain Florida criminal defendants were charged with driving under the influence (DUI), they sought the computer source codes of the breathalyzer equipment manufactured by CMI, Inc., a Kentucky-based corporation, by serving CMI's registered agent in Florida. The source code material was not located in Florida. The court of appeal held that criminal defendants must follow the procedures set forth in the Uniform Law to Secure the Attendance of Witnesses from Within or Without a State in Criminal Proceedings (Uniform Law) when requesting this source code material from out-of-state, nonparty witnesses and that service on CMI's registered agent was insufficient to compel CMI to produce the source codes. The Supreme Court approved of the court's decision, holding (1) in criminal cases, in order to subpoena documents located in another state that are in the possession of an out-of-state nonparty, the party requesting the documents must utilize the procedures of the Uniform Law; and (2) the issuance of the subpoenas at issue in this case lacked the statutory authority to require the out-of-state records custodian to comply because the criminal defendants did not first follow the procedures required by the Uniform Law.View "Ulloa v. CMI, Inc." on Justia Law

Petitioner was convicted of several crimes. The Fifth District Court of Appeal affirmed the convictions and sentences on direct appeal. Petitioner subsequently filed a motion for postconviction relief. The trial court partially granted relief on Petitioner’s sentencing claim, thus ordering resentencing, and partially denied relief as to Petitioner’s remaining postconviction claims. Fifteen days later, Petitioner filed a motion for rehearing challenging the denial of his other postconviction claims. The trial court denied relief. The Fifth District dismissed Petitioner’s appeal for lack of jurisdiction, determining that the trial court’s order partially denying and partially granting postconviction relief was not final until Petitioner’s resentencing was completed. The Supreme Court quashed the Fifth District’s decision, holding that an order disposing of a postconviction motion which partially denies and partially grants relief is a final order for purposes of appeal, even if the relief granted requires resentencing. View "Taylor v. State" on Justia Law

After a jury trial at which Appellant represented himself, Appellant was convicted of the first-degree murders of his parents and sentenced to death. The Supreme Court affirmed the convictions and death sentences, holding (1) the trial court did not err by allowing Appellant to continue to represent himself during a hearing regarding Appellant’s competence to proceed; (2) Appellant’s challenge to the constitutionality of Florida’s capital sentence statute under Ring v. Arizona was without merit; (3) competent, substantial evidence supported the convictions; and (4) the death sentences imposed in this case were proportionate. View "Larkin v. State" on Justia Law

Appellant was convicted of two counts of first-degree murder. The trial court imposed two death sentences after finding several aggravating factors. The Supreme Court affirmed on direct appeal. After Appellant's initial motion for postconviction relief was denied, Appellant filed a motion for DNA testing, which was also denied. Appellant subsequently filed in federal court a petition for a writ of habeas corpus, which was denied. Appellant then filed a successive postconviction motion, claiming that the American Society of Addiction Medicine (ASAM) Public Policy Statement defining addiction as a brain disorder was newly discovered evidence which, if presented to a jury, would probably result in a life sentence. The circuit court summarily denied the claim. The Supreme Court affirmed, holding that the ASAM definition was not newly discovered evidence, and even if the ASAM policy statement was considered to be newly discovered evidence and it was admitted at trial, it was not probable Appellant would receive a life sentence.View "Henry v. State" on Justia Law