Justia Florida Supreme Court Opinion Summaries

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

This case was before the Court for review of the decision of the Second District Court of Appeal in Zeigler 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 reasoning in Zeigler 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 "Zeigler v. State" on Justia Law

Defendant was convicted of the 1990 murder of a convenience store clerk and was sentenced to death. Defendant appealed the postconviction court's order summarily denying his successive motion for postconviction relief, filed pursuant to Florida Rule of Criminal Procedure 3.851, which challenged his conviction on the basis that a newly discovered witness significantly impeached the testimony of the only witness who identified defendant as leaving the crime scene immediately after the murder. The court reversed and remanded the Giglio v. United States and Brady v. Maryland claims to the postconviction court for an evidentiary hearing but denied the newly discovered evidence claim where the information provided by the new witness was not of such a nature that it would probably produce an acquittal on retrial. View "Mungin v. State" on Justia Law

This case was before the court on direct appeal from a judgment of conviction of first-degree murder and a sentence of death where defendant's convictions were based on the 2008 killing of a 13-year-old girl. Defendant raised several issues on appeal and the court disposed of each issue. The court affirmed defendant's convictions for sexual battery involving great physical force, aggravated child abuse, and first-degree murder. The court also affirmed the sentence of death. View "Caylor v. State" on Justia Law

Petitioner, an inmate in state custody, filed a pro se petition for writ of habeas corpus with the court seeking relief from an allegedly illegal sentence. The court denied the petition by way of an unpublished order, determining that it raised a repetitive claim addressed in a previous petition filed with the court. The court held, however, that in disposing the petition, the court expressly retained jurisdiction to pursue possible sanctions against petitioner. The court took notice that petitioner had compiled a history of pro se filings that, like the instant petition, were devoid of merit or inappropriate for review in the court. Accordingly, the clerk of the court was instructed to reject any future pleadings, petitions, motions, documents, or other filings submitted by petitioner unless such filings were signed by a member in good standing with The Florida Bar. View "James v. Tucker, Etc." on Justia Law