Justia Florida Supreme Court Opinion Summaries

Defendant was convicted of the first-degree shooting murder of a deputy sheriff, the attempted murder of another deputy sheriff, and armed robbery. Defendant was sentenced to death. Both defendant and the State raised issues on appeal. The court held that the trial court did not abuse its discretion in admitting photographic evidence and a vial of blood; in admitting a bullet fragment into evidence; and in failing to instruct the jury that defendant was not guaranteed parole at or after 25 years. The court also held that, because defendant failed to demonstrate that any of his claims amounted to error, defendant's claim of cumulative error was denied. The court finally held that, when compared with other capital cases, the death sentence in defendant's case was proportionate. View "Armstrong v. State of Florida" on Justia Law

Defendant appealed his conviction of first-degree murder and sentence of death. The court held that the trial court did not abuse its discretion in accepting defendant's request to waive the presentation of mitigation during the penalty phase where the trial court complied with the three-part procedure in Koon v. Dugger and complied with the Muhammad v. State requirements. The court also affirmed the trial courts finding of cold, calculated, and premeditated (CCP) and especially heinous, atrocious, or cruel (HAC) aggravators. The court court further held that because the trial court did not abuse its discretion, the court would not reweigh the trial court's assignment of weight. Therefore, the court held that defendant's death sentence was proportionate. The court finally held that a review of the record revealed that defendant's plea was made knowingly, intelligently and voluntarily. Therefore, the plea and conviction were properly entered. Further, the factual basis for the plea, which was confirmed by defense counsel and defendant, and was proven by the forensic evidence and defendant's confessions, provided competent, substantial evidence to support the conviction and sentence. View "Russ v. State of Florida" on Justia Law

Defendant was convicted of trafficking in cocaine and sale or possession of cocaine within 1000 feet of a church. At issue was whether the trial judge's arbitrary policy of rounding up sentences constituted a due process violation that was fundamental error reviewable on appeal without contemporaneous objection. The court held that the sentence imposed was within the legal guidelines - it was above the minimum required by the scoresheet and below the statutory maximum, but the trial judge's stated policy "improperly extended" defendant's incarceration in an arbitrary manner. Therefore, because this policy of "rounding up" violated defendant's right to due process, the court quashed the decision and remanded with directions that the trial court be directed to enter a sentence at the bottom of the guidelines and consistent with the reasoning expressed. View "Cromartie v. State of Florida" on Justia Law

Appellant, a prisoner under sentence of death, appealed the denial of his amended successive motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.851. Defendant raised numerous claims, including an Eighth Amendment challenge to the Florida Department of Correction's (DOC) lethal injection protocol, which replaced the first drug in its three-drug sequence, sodium thiopental, with another drug, pentobarbital sodium. The court held that, after reviewing the evidence and testimony, appellant had failed to satisfy the "heavy burden" that Florida's current lethal injection procedures, as implemented by the DOC, were constitutionally defective in violation of the Eighth Amendment. The court affirmed the circuit court's orders and vacated the temporary stay on execution. View "Valle v. State of Florida" on Justia Law

Defendant was convicted of first degree murder, both premeditated and felony murder, as well as other felony counts, and sentenced to death. On instant appeal, defendant raised claims of ineffective assistance of trial counsel pertaining to both the guilt and penalty phase of trial and raised a claim arising after the court's remand to the circuit court, challenging the fairness of the postconviction evidentiary hearing based upon the denial of his motion to disqualify the circuit judge and the exclusion of certain testimony and evidence at the hearing. The court discussed each claim and held that the circuit court's order denying defendant's Florida Rule of Criminal Procedure 3.851 amended motion was affirmed. View "Mendoza v. State" on Justia Law

Defendant appealed the denial of his amended and supplemental motions for postconviction relief and petitioned for writ of habeas corpus where he was convicted of first degree murders and sentenced to death for the commission of a triple homicide. Defendant raised numerous claims before the court on appeal but focused primarily on two of those claims: whether the state presented expert testimony on comparative bullet lead analysis (CBLA), which evidence had now established was no longer a reliable science, and whether newly discovered evidence showed that a critical state witness testified untruthfully. The court held that the 2008 letter at issue clearly qualified as newly discovered evidence; thus, the postconviction court erred in finding that the claim was procedurally barred and that the letter did not constitute newly discovered evidence. Regardless of these errors, the court affirmed the postconviction court's denial of relief because defendant could not demonstrate that consideration of the letter would probably produce an acquittal on retrial under the newly discovered evidence standard. The court also held that, as to the Brady v. Maryland and Giglio v. United States claims, there was no basis for concluding that the state withheld favorable evidence under Brady or knowingly presented evidence at the original trial under Giglio. After the FBI discovered the errors in the original CBLA evidence introduced at trial, defendant was made aware of these errors by letter. The court rejected defendant's ineffectiveness claim because the record showed that trial counsel retained an independent expert to evaluate the FBI's CBLA and the expert provided counsel with no basis to challenge that analysis. Therefore, the court affirmed the postconviction court's denial of relief and also denied defendant's habeas petition. View "Wyatt v. State; Wyatt v. Buss" on Justia Law

Defendant appealed from a judgment of conviction of first degree murder and a sentence of death. Defendant was also convicted of home invasion robbery with a firearm, kidnapping, and aggravated fleeing and eluding a law enforcement officer. Defendant raised various issues on appeal regarding his post-arrest interrogation; letter of apology; victim impact statements; how the murder was committed in a cold, calculated, and premeditated manner; how the murder was especially heinous, atrocious, or cruel; proportionality of the sentence; Ring v. Arizona; and sufficiency of the evidence. The court addressed each of defendant's claims and held that the convictions and sentences were affirmed. View "Baker v. State" on Justia Law

Defendant was convicted of four counts of first-degree murder and was sentenced to death for each of the murders. On direct appeal, defendant raised eleven claims regarding his competency at trial, his self-representation, limitations on his narrative testimony, the prosecutor's closing argument, evidence of collateral acts, removals from the courtroom, penalty phase jury instructions, his limitation on mitigating evidence, sufficiency of the evidence, and proportionality review of the sentence. The court addressed each claim and concluded that defendant's convictions and sentences of death were affirmed. View "McCray, II v. State" on Justia Law

Defendant was arrested and charged with possession of cannabis in an amount greater than 25 pounds, but less than 2000 pounds. Defendant filed a motion to suppress all evidence seized based on the May 16, 2007 warrant. At issue was whether a law enforcement officer's failure to sign an affidavit in support of a search warrant invalidated the warrant. The court held that the failure of the law enforcement officer to sign the affidavit did not render the search warrant invalid because, based upon all the circumstances surrounding the issuance of the warrant, the error constituted a technical flaw. Accordingly, the trial court erred by suppressing the evidence exclusively on that basis. View "Moreno-Gonzalez v. State" on Justia Law

Petitioner, a juvenile, was convicted for trespassing upon the grounds of a school facility in violation of section 810.097(2), Florida Statutes. At issue was whether the prosecution must prove the identity of the individual who warned defendant to leave the grounds of the school, and that individual's authority to restrict access to the property, as essential elements of the trespass offense. The court held that the individual's identity and authority were essential elements of the offense and quashed the decision of the Third District. The court also held that, because in this case the state failed to present any evidence demonstrating that the petitioner was warned to leave by the school's principal or a designee of the principal, petitioner's conviction must be vacated. View "D.J. v. State" on Justia Law