Justia Florida Supreme Court Opinion Summaries

Defendant was convicted on three counts of first-degree murder and sentenced to death on each count. Defendant appealed an order denying a second successive motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, claiming that he was deprived of effective trial counsel during the penalty phase because that phase was conducted before a jury that returned a death recommendation in violation of Porter v. McCollum. The court held that the trial level postconviction court properly denied defendant's second successive postconviction motion because the decision in Porter did not constitute a fundamental change in the law that mandated retroactive application under Witt v. State. Therefore, the court affirmed the judgment. View "Walton v. State" on Justia Law

Defendant appealed his conviction of first degree murder and sentence of death. Defendant raise six claims on appeal: (A) the trial court erred in denying several motions in limine; (B) the trial court erred in admitting the testimony of a DNA analyst from defendant's first trial; (C) the trial court erred at the guilt phase in denying the jury's request to view the indictment or have the indictment read to them; (D) the trial court erred at the penalty phase by providing improper instructions to the jury; and (E) the death sentence was not proportionate. The court held that none of these claims warranted relief and affirmed defendant's conviction and sentence. View "Partin v. State" on Justia Law

Defendant, a prisoner under sentence of death, appealed the denial of his amended and supplemental motions for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.850. Defendant raised the following claims on appeal: (1) the postconviction court erred in denying his claims pertaining to comparative bullet lead analysis (CBLA) and certain testimony; (2) trial counsel rendered ineffective assistance of counsel during the penalty phase; (3) trial counsel was ineffective in failing to object to the introduction of gruesome photographs; (4) defendant's rights were violated when he was improperly shackled during his trial; (5) Florida Rule of Criminal Procedure 3.852 was unconstitutional; (6) the penalty-phase jury instructions were unconstitutional; and (7) Florida's death penalty statute was unconstitutional. The court summarily denied claims 3, 4, and 6 as insufficiently pled. The court also denied without discussion of defendant's challenge pertaining to rule 3.852, based on the reasoning the court employed in ruling on his claim in defendant's postconviction appeal relating to the Domino's Pizza murders. The court further denied claim 7, challenging the constitutionality of the death penalty, based on the court's well-established precedent. Defendant had not made any additional allegations that would call into question the State's current methods of execution. Accordingly, the court affirmed the postconviction court's denial of relief and also denied defendant's habeas petition. View "Wyatt v. State; Wyatt v. Tucker, etc." on Justia Law

Petitioner, an inmate in state custody, filed a pro se petition for writ of mandamus with the court. Petitioner's petition was the twenty-seventh notice of extraordinary writ petition he had filed with the court since 2000. The court held that, because petitioner abused the limited judicial resources of the court, sanctions were warranted. View "Hastings v. State" on Justia Law

Defendant was convicted of first-degree murder, burglary of a dwelling, sexual battery with physical force, kidnapping, and robbery. Defendant, a prisoner under sentence of death, appealed from the denial of his motion for postconviction relief filed under Florida Rule of Criminal Procedure 3.851. Specifically, defendant contended that defense counsel provided constitutionally ineffective assistance in the penalty phase when (A) defense counsel failed to develop and present evidence that defendant suffered from intermittent explosive disorder; (B) defense counsel failed to use a mitigation specialist; and (C) defense counsel failed to present evidence of defendant's drug abuse as mitigation. The court held that defendant failed to meet his burden under Strickland v. Washington and because each of his claims of error failed individually, he was not entitled to relief for cumulative error. Accordingly, the court affirmed the denial of defendant's motion. View "Hoskins v. State" on Justia Law

In this case, the court considered the timeliness of a claim raised under Florida Rule of Criminal Procedure 3.850 that the Office of the Statewide Prosecutor (OSP) lacked jurisdiction to prosecute defendant. Because the court concluded that any lack of jurisdiction by the OSP did not divest the circuit court of jurisdiction, the court declined to address the certified conflict issue. Instead, the court resolved the case on the ground that defendant's challenge to the jurisdiction of the OSP was barred by the time limitations of rule 3.850. Accordingly, the court approved the Second District's affirmance of the trial court's denial of defendant's motion. The court disapproved Luger v. State and Winter v. State. To the extent that an error regarding the jurisdiction of the OSP rendered a conviction void ab initio, the court likewise disapproved Small v. State, Brown v. State, and Zanger v. State. View "Carbajal v. State" on Justia Law

This case was before the Court for review of the decision of the Second District Court of Appeal in Burgos v. State. The district court certified that its decision was in direct conflict with the decision of the First District Court of Appeal in Montgomery v. State. The court held that the district court's reliance upon Zeigler v. State was inconsistent with the court's reasoning in Montgomery and the court's conclusion that the use of the erroneous manslaughter by act instruction constituted fundamental error that required reversal of Montgomery's conviction for second-degree murder. Accordingly, the court accepted jurisdiction and granted the petition for review. View "Burgos, Jr. v. State" on Justia Law

This case was before the Court for review of the decision of the Third District Court of Appeal in Valdes-Pino v. State. The district court certified that its decision was in direct conflict with the decision of the First District Court of Appeal in Montgomery v. State. The court held that the district court's reliance upon Zeigler v. State was inconsistent with the court's reasoning in Montgomery and the court's conclusion that the use of the erroneous manslaughter by act instruction constituted fundamental error that required reversal of Montgomery's conviction for second-degree murder. Accordingly, the court accepted jurisdiction and granted the petition for review. View "Valdes-Pino v. State" on Justia Law

Defendant sought review of the decision of the Third District Court of appeal in Solano v. State on the ground that it expressly and directly conflicted with a decision of the Court in State v. Montgomery. Having issued its decision in Solano one day before the court issued its opinion in Montgomery, the district court did not have the benefit of considering Montgomery. Accordingly, the court accepted jurisdiction and granted defendant's petition for review. View "Solano v. State" on Justia Law

This case was before the Court for review of the decision of the Third District Court of Appeal in Bonilla v. State. The district court certified that its decision was in direct conflict with the decision of the First District Court of Appeal in Montgomery v. State. The court held that the district court's reliance upon Zeigler v. State was inconsistent with the court's reasoning in Montgomery and the court's conclusion that the use of the erroneous manslaughter by act instruction constituted fundamental error that required reversal of Montgomery's conviction for second-degree murder. Accordingly, the court accepted jurisdiction and granted the petition for review. View "Bonilla v. State" on Justia Law