Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of burglary of a dwelling with an assault or battery with a dangerous weapon, robbery with a weapon, and carjacking with a dangerous weapon. The court of appeal affirmed Defendant's convictions for burglary of a dwelling and carjacking but certified conflict on the issues of (1) whether Florida's burglary statute requires a structure to be suitable for habitation on the date of the offense for the structure to meet the definition of a dwelling, and (2) whether a defendant can be convicted of carjacking where the force used in the robbery on the inside of the building is separate from the taking of the vehicle on the outside of the building. The Supreme Court affirmed the court of appeal, holding (1) a structure undergoing substantial renovations constitutes a "dwelling" under the relevant statute; and (2) Defendant's actions constituted a carjacking under the relevant statute. View "Young v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder, two counts of robbery, and two counts of kidnapping. The trial court sentenced Defendant to concurrent sentences of death for both murders. The Supreme Court affirmed the convictions and sentences of death. Defendant subsequently filed a motion for postconviction relief, alleging that his trial counsel provided ineffective assistance. The postconviction court denied all of Defendant's claims. The Supreme Court affirmed the denial of relief and denied Defendant's petition for a writ of habeas corpus, holding (1) trial counsel did not provide constitutionally defective assistance; (2) Florida's death sentencing scheme is constitutional; and (3) Defendant's appellate counsel did not provide ineffective assistance. View "Jackson v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed the first-degree murder conviction and death sentence, holding (1) the trial court did not err in finding a cold, calculated and premeditated aggravator; (2) Defendant's death sentence was proportionate; (3) the penalty-phase jury instructions did not violate Caldwell v. Mississippi, and Ring v. Arizona did not require the reversal of Defendant's death sentence; (5) the trial court did not err in refusing to permit Defendant to present guilt-phase evidence of his mental condition at the time of the murder; and (6) competent, substantial evidence supported the verdict beyond a reasonable doubt. View "Brown v. State" on Justia Law

Petitioner, convicted of first-degree murder of a state correctional officer, appealed an order of the circuit court denying his motion to vacate his death sentence under Florida Rule of Criminal Procedure 3.851 and petitioned for a writ of habeas corpus. The court rejected petitioner's claim of ineffective assistance of trial counsel, concluding that it was reasonable for trial counsel to not challenge the intended sexual battery evidence on undue prejudice grounds and the court's confidence in the trial court's conclusion was not undermined by the possibility of additional evidence about the effect of petitioner's childhood on his mental status. The court also concluded that, because petitioner's challenges to Florida's death penalty scheme were meritless, appellate counsel did not err by failing to raise the arguments on direct appeal and petitioner was not entitled to habeas relief. Accordingly, the court affirmed the denial of postconviction relief and denied the petition for a writ of habeas corpus. View "Smith v. State" on Justia Law

Defendant appealed his conviction for first-degree murder and sentenced of death. On appeal, defendant raised eighteen claims of error and the State raised a claim regarding the proportionality of the death sentence in this case. The court concluded that defendant's claims were without merit, with the exception of Issue 2 regarding the scope of cross-examination. However, the court concluded that this error was harmless. The court also concluded that the death sentence was proportionally warranted in this case. Accordingly, the court affirmed the conviction and sentence. View "Gosciminski v. State" on Justia Law

Defendant was charged with burglary, grand theft, dealing in stolen property, and providing false information to a pawnbroker. The trial court refused to refer to Fla. Stat. 812.025 in its jury instructions or otherwise instruct the jury that it was precluded from finding Defendant guilty of both dealing in stolen property and theft. Defendant was convicted of all of the charges, but the trial judge subsequently dismissed the grand theft conviction. Defendant appealed, arguing that he was entitled to a new trial because the trial court denied his requested instruction modeled on section 812.025. The court of appeal affirmed. The Supreme Court quashed the decision of the court of appeal, holding (1) a trial court must instruct the jury pursuant to section 812.025 when both theft and dealing in stolen property offenses are submitted to the jury; (2) if a trial court denies a defendant's request for a jury instruction under section 812.025, the defendant must be given a new trial if the jury convicts the defendant of both theft and dealing in stolen property; and (3) Defendant was entitled to a new trial on the dealing in stolen property and grand theft counts. View "Williams v. State" on Justia Law

Defendant was charged with burglary, petit theft, and dealing in stolen property. The trial court did not instruct the jury it could not return a guilty verdict for both theft and dealing in stolen property pursuant to Fla. Stat. 812.025, and Defendant did not request such an instruction. The jury found Defendant guilty of both offenses. Defendant appealed, asserting that he was entitled to a new trial because he was convicted of both petit theft and dealing in stolen property in violation of section 812.025. The district court concluded that although Defendant did not object to the dual convictions at trial, he was permitted to challenge the convictions on appeal. The court then vacated the petit theft conviction. The Supreme Court affirmed, holding (1) although the trial court erred in rendering the dual convictions, it was not fundamental error such that would require a new trial; and (2) accordingly, the district court properly affirmed Defendant's dealing in stolen property conviction while reversing his petit theft conviction. View "Blackmon v. State" on Justia Law

On May 13, 2013, the Governor signed a death warrant for Defendant and set the execution date. After Defendant's state counsel wrote the Governor a letter stating there was reason to believe Defendant was insane to be executed, a group of psychiatrists conducted an examination of Defendant and concluded that Defendant was sane to be executed. Defendant's federal counsel subsequently filed a motion for stay and hearing, challenging Defendant's competency to be executed. After an evidentiary hearing, the circuit court found Defendant sane to be executed and lifted its stay. The Supreme Court affirmed, holding that competent, substantial evidence supported the circuit court's determination that Defendant was sane to be executed. View "Gore v. State" on Justia Law

In 2003, Petitioner was convicted of committing various offenses and was sentenced to terms of imprisonment. Petitioner subsequently filed numerous nonmeritorious pleadings and requests for relief related to his criminal convictions. Petitioner's petitions in the instant cases were denied as procedurally barred in 2012, and Petitioner was ordered to show cause why he should not be barred from filing in the Court any future pro se pleadings or requests for relief pertaining to his criminal convictions. After Petitioner failed to file a response, the Supreme Court barred Petitioner from any future pro se filings related to his criminal convictions and concluded that Petitioner's petitions in these cases were frivolous proceedings initiated by a prisoner. View "Werdell v. Crews" on Justia Law

Among other crimes, Defendant pleaded guilty to the first-degree murder of Michelle Simms and was sentenced to death. The Supreme Court vacated the death sentence and remanded. After the second sentencing proceeding, the trial judge imposed the death sentence for the first-degree murder. Defendant subsequently filed a postconviction motion, raising claims of ineffective assistance of counsel. The circuit court denied relief on all claims. The Supreme Court affirmed the trial court's denial of Defendant's postconviction motion, holding that the circuit court (1) did not err in denying Defendant's claim of ineffective assistance of defense counsel regarding Defendant's guilty plea; and (2) did not err in summarily denying Defendant's claim of ineffective assistance of counsel for failure to object to prosecutorial misconduct during the penalty phase. View "Long v. State" on Justia Law