Justia Florida Supreme Court Opinion Summaries

Defendant was charged with both grand theft and dealing in stolen property in connection with one scheme or course of conduct. Defendant argued that under Fla. Stat. 812.025, the trial court was required to instruct the jury that it could convict him of either grand theft or dealing in stolen property, but not both. The trial court rejected Defendant’s argument. A jury returned guilty verdicts of both offenses. The State subsequently filed a motion to dismiss the grand theft charge, which the trial court granted. Defendant unsuccessfully filed a motion for a new trial, asserting that the trial court erred by failing to comply with section 812.025. The court of appeal affirmed the convictions. The Supreme Court stayed proceedings pending disposition of Williams v. State, 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 "Crosby v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder. Appellant was sentenced to death for the murders. The Supreme Court affirmed the convictions and sentences. Appellant subsequently filed a motion to vacate the convictions and sentences pursuant to Fla. R. Crim. P. 3.851, asserting four claims. The postconviction court summarily denied Appellant’s motion without an evidentiary hearing. Appellant appealed the summary denial of his motion and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of the Rule 3.851 motion and denied the petition for writ of habeas corpus, holding, among other things, that (1) Appellant was afforded constitutionally effective assistance of trial counsel; (2) Appellant’s allegation of improper argument by the prosecution was procedurally barred; and (3) Appellant’s claim that to execute him would be unconstitutional because he was mentally ill was without merit. View "McKenzie v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Appellant’s convictions of first-degree murder and his sentences of death on appeal. Appellant subsequently filed a motion to vacate judgment of conviction and death sentence. After an evidentiary hearing, the circuit court denied the motion. The Supreme Court affirmed the circuit court’s denial of Appellant’s postconviction motion and denied habeas relief, holding (1) trial counsel did not render constitutionally deficient assistance by failing to object to the striking of a minority venireperson, failing to object to certain comments made by the trial court and the State, failing to file a motion to preclude the State from seeking the death penalty, and failing to investigate and present certain mitigation evidence; (2) Florida’s method of execution by lethal injection did not violate Appellant’s constitutional rights; and (3) appellate counsel was not ineffective for failing to raise on appeal the unconstitutionality of the strike of the minority venireperson. View "Frances v. State" on Justia Law

Defendant was convicted of one count each of burglary with an assault or battery, a first-degree felony, and strong-arm robbery, a second-degree felony. The sentencing judge sentenced Defendant to concurrent life sentences for each conviction. Defendant subsequently filed a motion to correct an illegal sentence, alleging that a life sentence on the second-degree felony conviction was impermissible. The trial court granted the motion without holding a hearing and resentenced Defendant on the robbery count. Defendant appealed, arguing that he was entitled to be present at his resentencing. The Third District Court of Appeal affirmed. The Supreme Court held (1) resentencing Defendant in his absence was error because, under Fla. R. Crim. P. 3.180(a), Defendant was entitled to be present; but (2) the error was harmless because Defendant was serving a concurrent, true life sentence on another count, with no practical consequences. View "Jordan v. State" on Justia Law

After a jury trial, Defendant was convicted of sexual battery for penetrating the victim’s vagina with his penis and lewd or lascivious molestation for intentionally touching the victim’s breasts, genitals, genital area, buttocks, or the clothing covering them. On appeal, the Second District Court of Appeal reversed and remanded for the trial court to vacate Defendant’s conviction for lewd or lascivious molestation, concluding that double jeopardy prohibited convictions for both sexual battery and lewd or lascivious molestation in a single criminal episode. The Supreme Court quashed the decision of the Second District and remanded to the district court for an order affirming Defendant’s convictions, holding that Defendant’s convictions involved offenses of a separate character and type, which were distinct criminal acts that do no violate double jeopardy. View "State v. Drawdy" on Justia Law

In 1995, Petitioner was convicted of first-degree felony murder, aggravated child abuse, and sexual battery. The jury recommended the death penalty, and the trial court imposed the death penalty. The Supreme Court affirmed on appeal. In 2006, Petitioner filed a third amended motion to vacate the judgments of convictions and sentences, asserting fourteen claims of error. After an evidentiary hearing, the postconviction court denied Petitioner’s motion for postconviction relief. The Supreme Court affirmed the postconviction court’s denial of Petitioner’s motion for postconviction relief and denied his petition for a writ of habeas corpus, holding (1) Petitioner failed to establish that the State violated Brady v. Maryland and Giglio v. United States; and (2) Petitioner’s trial counsel did not provide ineffective assistance. View "Davis v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder and one count of home invasion robbery with a firearm. The trial court sentenced Appellant to death for the murders and to life imprisonment for the armed home invasion robbery conviction. On appeal, Appellant raised thirteen claims of error. The Supreme Court affirmed, holding (1) most of Appellant’s claims of error were without merit; (2) a comment made by the prosecutor during penalty phase arguments was error, and the trial court erred in failing to assign a specific weight to the HAC aggravator, but the errors were harmless beyond a reasonable doubt; and (3) Appellant’s convictions were supported by competent, substantial evidence. View "Gonzalez v. State" on Justia Law

Appellant, a prisoner under sentence of death, was convicted of two counts of premeditated first-degree murder, among other crimes. After Governor Rick Scott signed a death warrant, Appellant filed a successive postconviction motion filed under Fla. R. Crim. P. 3.851, claiming that the trial court committed several substantive and procedural errors that denied him a fair and impartial trial and that the circuit court erred in limiting his ability to file additional successive motions. The Supreme Court affirmed the circuit court’s order denying relief on all of Appellant’s claims, holding that the claims were procedurally barred and without merit. View "Hendrix v. State" on Justia Law

Petitioner was convicted of numerous crimes and sentenced to life imprisonment. Petitioner’s convictions and sentences were affirmed on appeal. Petitioner subsequently filed several pro se filings in the Supreme Court and other courts. In this case, Petitioner filed a pro se petition for writ of habeas corpus challenging his convictions and sentences, which the Supreme Court dismissed. Because Petitioner’s petition contained false information and because he filed eleven extraordinary writ petitions with the Supreme Court since 2012, the Court found that the petition filed by Petitioner contained false information and was a frivolous proceeding and directed the clerk of court to reject any future pleadings or other requests for relief filed by Petitioner related to his convictions or sentences. View "Williams v. Crews" on Justia Law

Petitioner was convicted of kidnapping, robbery, aggravated battery, burglary, and possession of a firearm by a convicted felon. After his convictions and sentences became final, Petitioner filed numerous pro se filings in the Supreme Court and other courts. Petitioner later filed a pro se petition for writ of habeas corpus challenging his convictions and sentences. The Supreme Court dismissed the petition and expressly retained jurisdiction to pursue possible sanctions against Petitioner. Because Petitioner’s petition in this case contained false information and because Petitioner had filed eleven extraordinary writ petitions with the Supreme Court since 2012, the Court found that the petition filed in this case was a frivolous proceeding and imposed sanctions. View "Williams v. Crews" on Justia Law