Justia Florida Supreme Court Opinion Summaries

Defendant, a prisoner under sentence of death, appealed the denial of his motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.851. In the instant appeal, defendant primarily criticized his counsel's performance at trial for failing to adequately challenge the State's circumstantial case. Defendant argued that counsel rendered ineffective assistance for stipulating to the fact that DNA matching the victim's DNA was derived from blood as opposed to some other source. Defendant also contended that counsel was ineffective for failing to retain and call an expert to challenge the State's scratch-marks expert. Defendant additionally challenged counsel's presentation of mental health mitigation during the penalty phase. After conducting an evidentiary hearing, the postconviction court denied relief on these claims, as well as summarily denying relief on defendant's challenge to the rules prohibiting juror interviews. The court affirmed the postconviction court's denial of all claims. View "Crain, Jr. v. State" on Justia Law

Petitioner was convicted of several crimes, including the kidnapping of his eleven-year-old son. At issue was whether a parent could lawfully be convicted of kidnapping his own child under section 787.01, Florida Statutes. The court held that the plain language of section 787.01 did not preclude a parent from being held criminally liable for kidnapping his or her own child. View "Davila v. State" on Justia Law

Defendant, a prisoner under sentence of death, appealed from a circuit court order denying postconviction relief in this capital case. At issue was the court's procedure regarding the issue of pro se representation by defendants in capital postconviction appeals. Based on its solemn duty to ensure that the death penalty was imposed in a fair, consistent, and reliable manner, as well as the court's administrative responsibility to work to minimize the delays inherent in the postconviction process, the court held that death-sentenced defendants could not appear pro se in postconviction appeals. Accordingly, defendant's motion to discharge counsel and appear pro se and appellate counsel's motion for leave to withdraw were denied. View "Gordon v. State" on Justia Law

Defendant shot and killed a convenience store clerk during a robbery and was subsequently tried and convicted of armed robbery and first degree murder. At issue was whether the facts supported the trail court's legal conclusion that defendant had established the first prong of the mental retardation standard, i.e. significantly subaverage general intellectual functioning. The court held that the circuit court erred as a matter of law in finding that defendant met the definition of mental retardation under Florida law and therefore vacated the circuit court's order granting defendant's postconviction motion. View "State v. Herring" on Justia Law

Defendant was convicted of two counts of first-degree murder for the stabbing deaths of his cousin's girlfriend and her four-year-old daughter. Defendant appealed his convictions and sentences of death. The court held that the trial court did not abuse its discretion in denying defendant's motion for mistrial and in finding no discovery violations. The court also held that there was no basis that would disqualify the jury from rendering a penalty recommendation. The court rejected defendant's challenge to the constitutionality of Florida's death sentencing scheme. The court further held that the record demonstrated that there was competent, substantial evidence to sustain defendant's convictions. The court finally held that based on the evidence set forth, the aggravators the trial court found, and the totality of the circumstances, defendant's death sentences were proportionate compared to other death sentences the court had upheld. Accordingly, the court affirmed the convictions and sentences. View "Knight v. State" on Justia Law

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