Justia Florida Supreme Court Opinion Summaries

Articles Posted in Criminal Law
by
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

by
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

by
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

Posted in: Criminal Law
by
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

Posted in: Criminal Law
by
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

Posted in: Criminal Law
by
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

Posted in: Criminal Law
by
After a jury trial, Defendant was convicted of three counts of sexual battery and one count each of kidnapping, aggravated battery, and attempted robbery. Defendant was sentenced to life imprisonment for each sexual battery count and the kidnapping count. Defendant appealed, arguing that the trial court abused its discretion in refusing to give a curative instruction relating to statements the prosecutor made during voir dire. The Second District Court of Appeals found that the prosecutor’s remarks were improper but that there was “no reasonable possibility that the failure to give a curative instruction affected the verdict.” The Supreme Court quashed the Second District’s decision, holding that the prosecutor impermissibly commended during voir dire on Defendant’s constitutional right to remain silent, and the comments were not harmless beyond a reasonable doubt. View "Marston v. State" on Justia Law

by
After a jury trial, Defendant was convicted of first-degree murder and armed robbery with a firearm. Defendant was sentenced to death for the murder conviction. The Supreme Court (1) affirmed Defendant’s convictions, holding that the evidence was sufficient to support the verdicts of guilt; but (2) vacated the sentence of death, holding that a death sentence in this case was not proportionate to other cases in which the sentence of death has been upheld, and in fact, this case was indistinguishable from other cases involving the single aggravator of a murder during the commission of a robbery where the death penalty has been vacated. Remanded for imposition of a life sentence without the possibility of parole. View "Yacob v. State" on Justia Law

Posted in: Criminal Law
by
After a jury trial, Appellant was convicted of two counts of first-degree murder, armed robbery with a deadly weapon, and arson. Appellant was sentenced to death for the murders. Appellant’s death warrant was signed and his execution set for March 20, 2014. Appellant filed several post-trial motions, all of which were denied. In this appeal, Appellant challenged the denial of his second successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, his motion to declare Fla. Stat. 922.052 unconstitutional, and his motion to dismiss his death warrant. The Supreme Court affirmed the postconviction court’s denial of relief on all three motions and denied Appellant’s motion for a stay of execution, holding that the postconviction court did not err in its judgment. View "Henry v. State" on Justia Law

by
In this case, the district court concluded that satisfying the foundational requirements under the past recollection recorded exception to hearsay need not come from the declarant’s testimony. Afterwards, the Supreme Court decided Polite v. State, in which the Court held that the past recollection recorded exception requires the witness to indicate that the events were fresh in her mind when the statement was made, as well as to attest to the accuracy of the memorandum or record. Because the victims in this case did not vouch at trial for the accuracy or correctness of their written statements, the Supreme Court quashed the district court’s decision and remanded for reconsideration in light of Polite. View "McNeal v. State" on Justia Law