Justia Florida Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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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

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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

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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

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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

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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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