Justia Florida Supreme Court Opinion Summaries

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

Appellant was sentenced to death for the 2000 murders of an elderly couple. The Supreme Court affirmed Appellant's convictions but reversed the death sentences and remanded for a new penalty phase. After a new penalty phase, the trial court followed the jury's recommendation and imposed two death sentences for the murders. The Supreme Court affirmed the sentences, holding that the trial court did not err in (1) finding that Appellant was not mentally retarded; (2) admitting a video of a statement Appellant made to law enforcement; (3) instructing the jury on its advisory role and denying Appellant's proposed instruction regarding victim impact evidence; (4) allowing the prosecution to cross-examine mental health experts regarding their knowledge of the facts surrounding the murders; and (5) considering and weighing several aggravators and mitigators. Lastly, the Court found that the prosecutor made permissible comments at closing argument and that the death sentence was proportionate in this case. View "Snelgrove v. State" on Justia Law

Defendant was convicted of first-degree murder and was sentenced to death. The Supreme Court affirmed Defendant's sentence. Defendant filed a postconviction motion alleging ineffective assistance of counsel. The postconviction court denied the motion after an evidentiary hearing. Defendant appealed and also filed a habeas corpus petition. The Supreme Court affirmed the trial court's denial of Defendant's postconviction motion and denied his habeas petition, holding (1) Defendant did not establish that he received ineffective assistance of counsel, and therefore, his postconviction motion was correctly denied; (2) cumulative error did not deprive Defendant of a fair trial; (2) Defendant's sentence did not constitute cruel and unusual punishment; (3) Florida death penalty statute is not unconstitutional as applied to Defendant; and (4) counsel was not ineffective for failing to allege that Florida's capital sentencing statute is unconstitutional on its face and as applied to Defendant. View "Merck v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended a death sentence. Following a Spencer hearing, the trial court sentenced Defendant to death upon determining that the State had proven beyond a reasonable doubt the existence of several statutory aggravators. The Supreme Court affirmed the conviction and sentence, holding (1) the evidence presented at trial was sufficient to support the first-degree murder conviction; (2) under the totality of the circumstances, the death sentence in this case was proportionate; (3) Florida's protocol for execution by lethal injection is constitutional; and (4) Florida's capital sentencing process is constitutional. View "Kocaker v. State" on Justia Law

Defendant was originally convicted in 1981 for murder and sentenced to death. After a series of appeals and postconviction motions, Defendant filed a successive motion to vacate his sentence. Specifically, Defendant asserted that he was mentally retarded pursuant to Atkins v. Virginia. The trial court held an evidentiary hearing on Defendant's motion in 2009. The court denied relief, determining that Defendant could not meet the first prong of the mental retardation standard to establish his mental retardation. The Supreme Court affirmed, holding that there was competent, substantial evidence to support the court's finding that Defendant was not mentally retarded. View "Hall v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder, one count of burglary with assault or battery while armed, and one count of criminal mischief. The trial court imposed death sentences for both murders. The trial court subsequently denied Defendant's motion for postconviction relief. Defendant appealed the trial court's denial of his motion and petitioned the Supreme Court for a writ of habeas corpus. The Court affirmed the denial of Defendant's postconviction motion and denied his habeas petition, holding, among other things, that (1) Defendant's trial counsel did not provide ineffective assistance during the guilt phase or the penalty phase; (2) the State did not violate Brady v. Maryland by withholding evidence; (3) trial counsel was not operating under an actual conflict of interest due to counsel's workload; (4) the trial court did not err in denying several of Defendant's requests for additional public records; and (5) Defendant was not entitled to relief on any of the claims he raised in his habeas petition. View "Dennis v. State" on Justia Law

Defendants pled nolo contendere to charges of violating the sound standards of Fla. Stat. 316.3045(1)(a), reserving the right to appeal the constitutionality of the statute. Defendants subsequently appealed, arguing that the statute's "plainly audible" standard was constitutionally vague, overbroad, invited arbitrary enforcement, and impinged on their free speech rights. Bound by the Second District's decision in Easy Way of Lee County v. Lee County, the circuit court reversed. On appeal, the Second District denied the State's petition for certiorari relief, holding (1) the "plainly audible" standard of noise ordinance was unconstitutional, and (2) section 316.3045(3) was an unconstitutional content-based restriction because it contained an exemption for vehicles used for business and political purposes that use sound-making devices in the normal course of operations. The Supreme Court (1) affirmed the Second District's declaration that section 316.3045(1)(a) was invalid because it was an unreasonable restriction on the freedom of expression; (2) held that the statute was unconstitutionally overbroad, but not unconstitutionally vague; and (3) found that section 316.3045(3) was not severable from the remainder of the statute. View "State v. Catalano" on Justia Law