Justia Florida Supreme Court Opinion Summaries

Defendant was convicted of the first-degree murder of Officer Donna Fitzgerald. Fitzgerald's body was found in the paint room at Tomoka Correctional Institute (TCI). After Defendant, an inmate at TCI, was apprehended by TCI personnel, Defendant repeated, "I freaked out. I snapped. I killed her." The trial court imposed the sentence of death. The Supreme Court affirmed Defendant's conviction and sentence, holding (1) the trial court properly denied Defendant's motion to suppress his confessions; (2) the trial court did not err in admitting opinion testimony of the medical examiner regarding the sequence of wounds and position of the victim; (3) the trial court's finding of a certain aggravator was in error, but the error was harmless; (5) the death sentence was appropriate; and (6) Florida's death sentencing scheme is not unconstitutional under Ring v. Arizona. View "Hall v. State" on Justia Law

Convicted of first-degree murder for causing the 2007 death of McKinness, Hampton was sentenced to death following the jury’s recommendation by a vote of nine to three. Hampton filed several motions seeking relief based on the allegation that one of the jurors was “under prosecution” at the time of his jury service. The trial court denied the motions. The Florida Supreme Court affirmed the conviction and sentence, rejecting challenges to the sufficiency of the evidence and the proportionality of the death sentence. View "Hampton v. State of Florida" on Justia Law

Section 893.13 of the Florida Comprehensive Drug Abuse Prevention and Control Act, provided that “it is unlawful for any person to sell, manufacture, or deliver, or possess with intent to sell, manufacture, or deliver, a controlled substance… or … to be in actual or constructive possession of a controlled substance.” The law did not specify the mental state required for conviction. In prior decisions, the Florida Supreme Court determined that knowledge of the presence of the substance and knowledge of the illicit nature of the substance were required. In response, the Legislature, in 2011, stated that the decisions were contrary to legislative intent. “The Legislature finds that knowledge of the illicit nature of a controlled substance is not an element of any offense under this chapter. Lack of knowledge of the illicit nature of a controlled substance is an affirmative defense.” The statute does not eliminate the element of knowledge of the presence of the substance. Since the enactment, each court of appeal has ruled that the statute does not violate requirements of due process. The U.S. District Court (M.D. Fla.) concluded, however, that it is unconstitutional. Based on that decision, a trial court dismissed a case under the Act. The Florida Supreme Court reversed. View "State of Florida v. Adkins" on Justia Law

Defendant was sentenced to death for a drug-related 1988 murder. The Florida Supreme Court reversed the circuit court's denial of post-conviction relief based on a claim of ineffective assistance of counsel during the penalty phase. Counsel rendered ineffective assistance by failing to investigate, develop, and present available mitigating evidence that would have legally precluded the trial court from overriding the jury's life recommendation. The evidence in question concerned the abuse defendant endured at the hands of his father and the extremely negative influence his father had on his life and that from a young age he witnessed violent acts being committed against his mother and others, including witnessing others being killed. View "Robinson v. State of Florida" on Justia Law

Delhall, was convicted of first-degree premeditated murder, unlawful use of a firearm, unlawful discharge of the firearm resulting in death or serious bodily harm, and possession of a firearm by a convicted felon. At the jury trial the State presented evidence that Delhall murdered the victim because he was, at that time, the only known eyewitness to the murder of another individual (Bennett) with which Delhall’s brother was charged. The jury recommended a death sentence by a vote of eight to four, and the trial court entered an order sentencing Delhall to death. The Florida Supreme Court vacated the sentence, stating that the prosecutor, “by her overzealous and unfair advocacy, appeared to be committed to winning a death recommendation rather than simply seeking justice.” Her improper advocacy continued even after an objection was sustained. In one instance, the judge was forced to step in and specifically admonish her to stop it. Cumulative errors fundamentally tainted the guilt phase, which was especially significant in view of the fact that the jury recommended death by a vote of eight to four, a recommendation that was far from unanimous. View "Delhall v. State of Florida" on Justia Law

Butler was convicted of first-degree murder and sentenced to death for the 1997 murder of his former girlfriend. The Florida Supreme Court affirmed the conviction and death sentence on direct appeal. Butler filed a motion to vacate his conviction and death sentence pursuant to Florida Rule of Criminal Procedure 3.851. The post-conviction court held three evidentiary hearings and denied relief. The Florida Supreme Court affirmed, rejecting claims that appellate counsel provided ineffective assistance by failing to file a petition for certiorari with the U.S. Supreme Court; appellate counsel provided ineffective assistance by abandoning the claim that a witness was incompetent to testify at trial; Florida’s lethal injection protocol constitutes cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments; and Butler’s right against cruel and unusual punishment will be violated because he may be incompetent at the time of execution. View "utler v. State of Florida" on Justia Law

Hackley was convicted of burglary of a conveyance with a person assaulted, arising out of a 2006 incident in which Hackley assaulted two individuals, one of whom was inside a car. Because the offense occurred less than three years after he had been released from serving another sentence in state prison, the trial court sentenced Hackley to life in prison as a prison releasee reoffender under section 775.082(9)(a)1, Florida Statutes. The trial court granted a motion to correct, finding that the crime for which he was convicted did not qualify him for PRR sentencing. The appeals court affirmed. Noting a conflict between districts, the Florida Supreme Court held that burglary of a conveyance with an assault is a qualifying offense under the PRR statute.View "State of Florida v. Hackley" on Justia Law

McMillian was sentenced to death for premeditated first degree murder of his girlfriend. He has given at least five different accounts of events relating to the murder; no two are wholly consistent with each other, and none can be fully reconciled with the evidence. The evidence collected at the scene of a shootout between McMillian and police and the scene of the murder, showed that McMillian’s gun was used in the murder. Evidence also included a security video from a convenience store near the victim’s townhome and phone records and McMillian’s confession. McMillian was approximately one year into a five-year term of felony probation stemming from an incident in Georgia in which McMillian fled police, who were attempting to pull him over, at speeds up to 120 m.p.h. through a residential neighborhood. The Florida Supreme Court affirmed the conviction and sentence. View "Mcmillian v. State of Florida" on Justia Law

Petitioner was found guilty of armed robbery of a convenience store when he was 19-years-old and was sentenced to life in prison as a habitually violent offender. At issue was the summary denial of an evidentiary hearing in postconviction proceedings under Florida Rule of Criminal Procedure 3.850. The court concluded that the district court misapplied the court's precedent and in so doing erred in affirming the summary denial of petitioner's successive motion for postconviction relief based on newly discovered evidence. Accordingly, the court quashed the decision below and remanded for an evidentiary hearing on the newly discovered evidence claim involving only the affidavit of the codefendant. View "Nordelo v. State" on Justia Law

Petitioner, an inmate in state custody, filed a pro se petition for writ of habeas corpus challenging his conviction and sentence. The court dismissed the petition in this case by way of an unpublished order, determining that the petition was unauthorized pursuant to Baker v. State. In disposing of the petition, the court expressly retained jurisdiction to pursue possible sanctions against petitioner. After considering petitioner's show cause response, the court concluded that it failed to show cause why he should not be sanctioned. Petitioner's unauthorized petition was a frivolous proceeding and petitioner had compiled a history of pro se filings that were devoid of merit or inappropriate for review. View "Gaffney v. Tucker, etc." on Justia Law