Justia Florida Supreme Court Opinion Summaries

Defendant was charged with the attempted first-degree murder of his ex-girlfriend in 2006. The jury instruction for attempted manslaughter by act was given consistent with the standard instruction as it existed in 2006. The instruction required the jury to find that Defendant "intentionally caused the death" of the victim. Defendant was ultimately convicted of attempted second-degree murder. Defendant appealed, contending that giving the instruction constituted fundamental error similar to that found by the Supreme Court in State v. Montgomery, in which the Court ruled that giving the standard jury instruction for the completed crime of manslaughter by act is fundamental error when the defendant is convicted of an offense not more than one step removed from manslaughter. The Court quashed the decision of the court of appeals and remanded the case, holding (1) giving the standard jury instruction on attempted manslaughter by act constitutes fundamental error where the defendant is convicted of an offense not more than one step removed from attempted manslaughter because the crime of attempted manslaughter by act does not require the State to prove that the defendant intended to kill the victim; and (2) the offense of attempted manslaughter remains a viable offense. View "Williams v. State" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death. After his initial postconviction motion was denied, Petitioner filed an amended successive postconviction motion to vacate his judgments and sentence. Defendant filed a motion for discovery with regard his postconviction claim of newly discovered evidence, seeking production of a photograph card of an unidentified fingerprint found on the victim's check, which Defendant sought to compare with that of a deceased death row inmate. The postconviction court denied Defendant's motion for discovery and summarily denied his amended successive postconviction motion. The Supreme Court affirmed, holding (1) the postconviction court correctly summarily denied relief on the postconviction motion, as (i) Defendant's claim was time-barred, and furthermore, the record showed Defendant was not entitled to relief; (ii) Defendant was not entitled to a new trial based on newly discovered evidence; and (iii) Defendant was not deprived of his due process rights to present evidence on his challenge to Florida's lethal injection procedures. The Court also affirmed the circuit court's denial of Defendant's motion for discovery, as Defendant did not show his request would result in discovery of relevant or material evidence. View "Reed v. State" on Justia Law

In 1976, Defendant was convicted of the first-degree murders of his wife Eunice Zeigler and Charlie Mays and the second-degree murders of his in-laws, Perry and Virginia Edwards. In 2001, the trial court granted Defendant's motion for DNA testing for the purposes of clemency proceedings. After the testing was completed, Defendant filed a motion to vacate his sentences, arguing that the presence of Perry's blood on Mays' clothing corroborated his testimony that Mays was a perpetrator rather than a victim. The trial court denied the motion, and the Supreme Court affirmed. In 2009, Defendant filed a motion for postconviction DNA testing requesting further testing of the victims' clothing. Following an evidentiary hearing, the circuit court denied Defendant's motion. The Supreme Court affirmed, holding that Defendant had not met his burden of showing how the results of the DNA testing would give rise to a reasonable probability of a different outcome. View "Zeigler v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and was sentenced to death. The Supreme Court affirmed Defendant's conviction and sentence, holding (1) Defendant's claims regarding the constitutionality of certain aggravators and jury instructions were denied because Defendant provided no reasons that the Court should depart from its precedent upholding the constitutionality of these aggravators and instructions; (2) competent, substantial evidence supported Defendant's murder conviction; and (3) under the totality of the circumstances, Defendant's death sentence was proportional in relation to other death sentences the Court has upheld. View "Matthews v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. Defendant appealed, contending, among other things, that the trial court erred when it denied his motion to suppress his confession because, during his interrogation and before he confessed to the murder, he invoked his right to remain silent. The Supreme Court reversed and remanded for a new trial, holding (1) based on the totality of the circumstances, the police did not scrupulously honor Defendant's invocation of his right to remain silent; (2) there was not competent, substantial evidence to support the trial court's finding that Defendant's confession was voluntary; and (3) the State failed to establish that this error was harmless beyond a reasonable doubt. View "Deviney v. State" on Justia Law

Defendant was convicted of first-degree murder. After a retrial, Defendant was again convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant's conviction and sentence, holding (1) the admission of testimony from Defendant's first trial did not violate Defendant's right to confrontation or to due process; (2) the trial court did not err in admitting a suicide note Defendant wrote while incarcerated; (3) the evidence was sufficient to support a first-degree murder conviction; (4) the trial court did not err in rejecting a proposed statutory mental mitigator; and (5) Defendant's death sentence was proportional in this case. View "Bolin v. State" on Justia Law

Defendant constructed a bomb with the specific purpose of killing a witness, but the bomb instead detonated and killed a highway patrol trooper. After a jury trial, Defendant was convicted of first-degree murder and of making, possessing, placing, or discharging a destructive device or bomb. Defendant was sentenced to death. After the execution was set for February 26, 2013, Defendant filed a successive motion for postconviction relief, which the trial court summarily denied. The Supreme Court affirmed the denial of Defendant's motion for postconviction relief and denied Defendant's motion for a stay of execution, holding (1) the trial court did not err in denying Defendant's motion to remove appointed registry counsel; (2) the trial court did not err in denying Defendant's motions to appoint experts and investigators; (3) the trial court did not err in finding that lethal injection did not constitute cruel and unusual punishment; and (4) Defendant failed to show that there were substantial grounds upon which relief might be granted regarding his application for a stay of execution. View "Howell v. State" on Justia Law

Defendant was charged with attempted first-degree murder. The jury was instructed on lesser included offenses, including attempted manslaughter by act. The instruction was given consistent with the standard instruction. Defendant was ultimately convicted of attempted second-degree murder. Defendant appealed, contending that giving the instruction constituted fundamental error similar to that found by the Supreme Court in State v. Montgomery, in which the Court held that giving the standard jury instruction for the completed crime of manslaughter by act - which required the jury to find that the defendant intended to kill the victim - was fundamental error when the defendant was convicted of an offense not more than one step removed from manslaughter because the manslaughter instruction does not require an intent to kill. The Supreme Court accepted certification to answer questions of law and held (1) the standard jury instruction on attempted manslaughter constitutes fundamental error where the defendant is convicted of an offense not more than one step removed from attempted manslaughter; and (2) the offense of attempted manslaughter remains a viable offense. View "Williams v. State" on Justia Law

Defendant was tried on the charge of second-degree murder. The jury was instructed without objection as to the lesser included offense of manslaughter, which included the instructions on manslaughter by act and manslaughter by culpable negligence. Defendant was found guilty of second-degree murder. Defendant appealed, alleging that fundamental error occurred when the jury was given the then-standard jury instruction on manslaughter by act, which the Supreme Court held to be fundamental error in State v. Montgomery. The Supreme Court accepted review in this case to answer a question certified to it by the court of appeal. The Court answered by holding that giving the erroneous manslaughter by act instruction is also fundamental error even if the instruction on manslaughter by culpable negligence is given where the evidence supports manslaughter by act but does not support culpable negligence, and the defendant is convicted of second-degree murder. View "Haygood v. State" on Justia Law

Defendant was convicted and sentenced for lewd and lascivious molestation on a victim under twelve years of age by an offender eighteen years of age or older and for failure to appear. Defendant appealed, arguing that certain comments made by a prosecutor during closing argument were improper. The court of appeal affirmed, holding, among other things, that because the victim's age was not an issue which only Defendant was capable of refuting, the prosecutor's comment in regard to the victim's age could not be construed as a comment on Defendant's right to remain silent. The Supreme Court affirmed, holding (1) the prosecutor's comment did not constitute an improper comment on Defendant's right to remain silent; (2) the court of appeal erred in holding that a second comment likewise did not constitute an improper comment on Defendant's right to remain silent and that two additional comments constituted improper burden shifting; but (3) the objections to the improper comments were not preserved for appellate review, and because the comments did not constitute fundamental error, they did not require reversal. View "Bell v. State" on Justia Law