Justia Florida Supreme Court Opinion Summaries

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

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