Justia Florida Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of first-degree murder and kidnapping and sentenced to death. Appellant appealed, arguing, among other things, that (1) the trial court erred in allowing the State to ask a law enforcement officer about statements Appellant made to him during an interview without admitting the entire interview under the rule of completeness; and (2) the trial court erred in finding the avoiding arrest and cold, calculated, and premeditated (CCP) aggravators. The Supreme Court affirmed, holding (1) Appellant failed to properly preserve his first claim, and even if he had, any error in not admitting the statements under the rule of completeness was harmless beyond a reasonable doubt; (2) the trial court erred in finding the avoiding arrest aggravator, but this error was harmless, and there was competent, substantial evidence to support the finding of CCP; (3) there was sufficient evidence to support Appellant's convictions; and (4) the death sentence was proportional in this case.View "Calhoun v. State" on Justia Law

Appellant was convicted of first-degree murder, burglary of a battery therein, and sexual battery with great force. Appellant was sentenced to death. The Supreme Court upheld the convictions and death sentence on appeal and later upheld the denial of postconviction relief and denied habeas relief. After Appellant was scheduled for execution, he filed a successive postconviction motion, claiming that Florida's death penalty statute violated the Eighth Amendment because most states require a unanimous jury verdict to recommend a death sentence and because alleged newly discovered evidence revealed that the number of defendants sentenced to death in Florida increased in 2012 compared to the rest of the nation. The circuit court denied relief. The Supreme Court affirmed, holding (1) non-unanimous jury recommendations to impose the sentence of death are not unconstitutional; and (2) the circuit court accurately found that the studies cited by Appellant in support of his second claim did not qualify as newly discovered evidence. View "Kimbrough v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The trial court concluded that the aggravating circumstances outweighed the mitigating circumstances and imposed upon Appellant the sentence of death. The Supreme Court affirmed Defendant’s conviction and sentence of death, holding (1) the trial court’s findings in support of the application of the cold, calculated, and premediated aggaravator were supported by competent, substantial evidence; (2) based on the totality of the circumstances and prior precedent, a sentence of death was proportionate in this case; (3) the evidence was sufficient to support Defendant’s conviction; and (4) Defendant was not entitled to relief on her claim that Florida’s death penalty statute violates Ring v. Arizona. View "Brown v. State" on Justia Law

Petitioner was convicted of aggravated assault with a firearm and sentenced as a prison releasee reoffender (PRR). Petitioner was also convicted of carrying a concealed firearm and possessing a firearm by a convicted felon and sentenced as a habitual felony offender (HFO). Petitioner was sentenced to a total of thirty-five years’ incarceration. The court of appeal affirmed Petitioner’s sentences. Petitioner subsequently filed a pro se motion for postconviction relief alleging that his thirty-five year sentence was illegal under Hale v. State, which held that sentences enhanced under the habitual violent felony offender provision of Fla. Stat. 775.084 cannot run consecutively to other sentences arising from the same criminal episode. The trial court denied Appellant’s motion for postconviction relief. The court of appeal affirmed, concluding that because the PRR statute imposes a mandatory minimum that is in accordance with, and not beyond, the statutory maximum, a PRR sentence is not an enhanced sentence, and a trial court may therefore impose an HFO sentence consecutive to a PRR sentence. The Supreme Court approved the court of appeal’s decision, holding that Hale does not prohibit a habitual offender sentence from being imposed consecutively to a PRR sentence. View "Cotto v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder, attempted first-degree murder, grand theft of a motor vehicle, home invasion robbery, and aggravated assault on a police officer. The trial court imposed a sentence of death for the murder conviction. The Supreme Court affirmed the convictions and sentences. Appellant subsequently filed a motion to vacate his conviction and sentence of death pursuant to Fla. R. Crim. P. 3.851, presenting ten claims. The postconviction court summarily denied all claims except Appellant’s claim of ineffective assistance of counsel. After an evidentiary hearing, the postconviction court denied Appellant’s ineffective assistance of counsel claim. The Supreme Court affirmed the trial court’s order denying postconviction relief, holding (1) Appellant’s trial counsel were not ineffective; and (2) Appellant’s challenges to the death penalty in Florida were either waived, procedurally barred, meritless, or premature. View "Turner v. State" on Justia Law

The State charged Defendant in a two-count information with unlawful commission of a sexual battery on a “mentally defective” person over the age of twelve. The jury returned guilty verdicts on both counts. The trial court set aside the guilty verdicts and dismissed the charges, concluding that the State had not presented sufficient credible evidence to satisfy its burden of proving that the victim was “mentally defective” beyond a reasonable doubt. The court of appeal reversed and reinstated the guilty verdicts, holding that the evidence was sufficient to support a jury finding that the victim was mentally defective. The Supreme Court approved the court of appeal’s decision, concluding that the court of appeal properly construed the sexual battery statute to determine that the term “mentally defective” connotes significantly diminished judgment and could not reasonably be read to mean a total lack of mental capacity. View "Dudley v. State" on Justia Law

After a jury trial, Appellant was convicted of one count of first-degree murder, four counts of armed kidnapping, and one count of armed robbery. Appellant was sentenced to death for the murder conviction. The Supreme Court affirmed, holding (1) the prosecutor’s method of impeachment after Appellant’s prior conviction record was entered into evidence was improper, but the error was harmless; (2) the State did not violate either the spirit or the technical requirements of the criminal discovery rules by refusing to transcribe a witness’s recorded statement for Defendant; (3) the trial court erred by prohibiting Appellant from attempting to refresh a witnesses’s recollection, but the error was harmless; (4) Appellant’s right to compulsory process was not violated; (5) the trial court erred in finding an avoid arrest aggravating circumstance, but the error was harmless; (6) Defendant’s death sentence was proportionate; and (7) there was sufficient evidence to support Appellant’s convictions. View "Wilcox v. State" on Justia Law

Appellant was convicted for the 1998 first-degree murder of Cynthia Harrison and sentenced to death. Concluding that the trial court erred in denying Appellant’s postconviction claim of ineffective assistance of counsel, the Supreme Court remanded for a new penalty phase hearing. The trial court subsequently entered an order sentencing Appellant to death. The Supreme Court affirmed the sentence, holding (1) the trial court did not err in finding that Appellant was not mentally retarded and exempt from execution; (2) constitutional error did not occur because the advisory jury in the penalty phase was not required to expressly find specific aggravators or issue a unanimous advisory verdict on the sentence; and (3) Appellant’s death sentence, when compared to the death sentences in other comparable capital cases, was proportionate. View "Hurst v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder and one count of armed carjacking. The trial court sentenced Defendant to death on both murder counts. The Supreme Court affirmed Defendant’s convictions and sentences. Defendant subsequently filed a motion for postconviction relief, raising twenty-eight claims. After an evidentiary hearing, the circuit court denied relief. Defendant appealed the denial of his postconviction motion, raising twenty-one claims, and also petitioned the Supreme Court for a writ of habeas corpus, raising two claims of ineffective assistance of appellate counsel. The Supreme Court affirmed the postconviction court’s denial of relief on all claims and denied habeas corpus relief, holding (1) Defendant failed to establish that any errors occurred that, either individually or cumulatively, would entitle him to a new guilt phase trial; and (2) Defendant’s claims of ineffective assistance of appellate counsel were procedurally barred. View "Deparvine v. State" on Justia Law

Defendant was charged with both grand theft and dealing in stolen property. Because the grand theft and dealing in stolen property charges arose from one scheme or course of conduct, the trial court dismissed the grand theft count. Defendant was then convicted of dealing in stolen property. Defendant appealed, arguing that the trial court should have instructed the jury that it could return a verdict for dealing in stolen property or grand theft, but not both. The court of appeal certified questions to the Supreme Court that the court certified in Williams v. State. The Supreme Court stayed proceedings pending disposition of Williams, in which the Court held that the defendant’s convictions for dealing in stolen property and grand theft violated Fla. Stat. 812.025 and that the trial court erred in precluding defense counsel from arguing that the jury could find the defendant guilty of either offense. After Williams was decided, the Supreme Court granted Petitioner’s petition for review, quashed the court of appeal’s decision, and remanded for further proceedings consistent with Williams. View "Culpepper v. State" on Justia Law