Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of kidnapping and first-degree murder. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant's convictions and sentence, holding (1) the trial judge did not err in admitting statements Defendant made to law enforcement because the statements did not constitute similar fact or collateral crime evidence and were otherwise relevant and admissible to establish premeditation; (2) because Defendant's expert testimony opened the door for a witness to testify about allegations of Defendant's past criminal conduct, the trial court properly admitted the testimony and properly excluded the witness from the sequestration rule; (3) substantial, competent evidence supported the trial court's fining that certain aggravating circumstances applied in Defendant's case; (4) the trial court properly rejected the lack of capacity mitigating factor; (5) the evidence was sufficient to support the convictions; and (6) the imposition of the death sentence in this case was proportionate when compared to other death sentences the Court has upheld. View "Hilton v. State" on Justia Law

Defendant was convicted of first-degree murder and kidnapping and sentenced to death for the first-degree murder and to fifteen years' imprisonment for kidnapping. The Supreme Court affirmed on direct appeal. Defendant subsequently filed a motion for postconviction relief. Following an evidentiary hearing, the circuit court denied postconviction relief on all claims. Defendant appealed the circuit court's denial of postconviction relief and also petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of Defendant's postconviction motion and denied his habeas petition, holding (1) the circuit court did not err in concluding that Defendant's postconviction claims were either procedurally barred, conclusively refuted by the record, facially or legally insufficient as alleged, or without merit as a matter of law; and (2) Defendant's counsel provided effective assistance, and therefore, Defendant's claims for habeas relief failed. View "Conahan v. State" on Justia Law

Plaintiff, the personal representative of the estate of Charlotte Douglas, filed a complaint against cigarette companies and industry organizations for damages on claims based on Charlotte's smoking-related death. After a jury trial, Plaintiff was awarded $2.5 million in damages. At issue on appeal was whether the trial court erred in the application of the Phase I findings in the class action case Engle v. Liggett Group, Inc. Charlotte was a member of the Engle class. The court of appeal affirmed, concluding that Plaintiff did not prove legal causation on his negligence theory but did prove legal causation on his strict liability claim. Although the court of appeal rejected Defendants' argument that applying res judicata to the findings violated their due process rights, it certified the due process question to the Supreme Court. The Court approved of the court of appeal's decision affirming the general verdict for Plaintiff based on strict liability but disapproved the court's rejection of negligence as a basis for the general verdict because the court's analysis required causation instructions and findings beyond those required by Engle. In addition, the Court answered that accepting as res judicata the eight Phase I findings approved in Engle did not violate Defendants' due process rights. View "Philip Morris USA Inc. v. Douglas" on Justia Law

The Florida Judicial Qualifications Commission (JQC) instigated formal proceedings against circuit court Judge R. Timothy Shea for the judge's rude and intemperate behavior. After the Supreme Court disapproved the proposed sanction, the JQC withdrew its findings and recommendation of discipline and subsequently filed amended formal charges against Judge Shea. Based on facts set out in a second stipulation, the JQC filed a second findings and recommendation of discipline, determining that Judge Shea engaged in inappropriate behavior that was unbecoming a member of the judiciary. The JQC recommended that Judge Shea receive a public reprimand with the additional requirement that the judge send letters of apology to those individuals identified in the notice of amended formal charges and continue to obtain mental health treatment as recommended by his doctor and family therapist. The Supreme Court approved the JQC's findings and recommended discipline based on the severity of the judge's misconduct and the mitigating factors in his case. View "In re Shea" on Justia Law

Defendant was charged with the attempted first-degree murder of his ex-girlfriend in 2006. The jury instruction for attempted manslaughter by act was given consistent with the standard instruction as it existed in 2006. The instruction required the jury to find that Defendant "intentionally caused the death" of the victim. Defendant was ultimately convicted of attempted second-degree murder. Defendant appealed, contending that giving the instruction constituted fundamental error similar to that found by the Supreme Court in State v. Montgomery, in which the Court ruled that giving the standard jury instruction for the completed crime of manslaughter by act is fundamental error when the defendant is convicted of an offense not more than one step removed from manslaughter. The Court quashed the decision of the court of appeals and remanded the case, holding (1) giving the standard jury instruction on attempted manslaughter by act constitutes fundamental error where the defendant is convicted of an offense not more than one step removed from attempted manslaughter because the crime of attempted manslaughter by act does not require the State to prove that the defendant intended to kill the victim; and (2) the offense of attempted manslaughter remains a viable offense. View "Williams v. State" on Justia Law

Tiara Condominium Association (Tiara) retained Marsh & McLennan (Marsh) as its insurance broker. Marsh secured windstorm coverage through Citizens Property Insurance Corporation (Citizens), which issued a policy that contained a loss limit in an amount close to $50 million. Tiara's condominium subsequently sustained damages caused by two hurricanes. After being assured by Marsh that the loss limits coverage was per occurrence, Tiara spent more than $100 million in remediation efforts. However, when Tiara sought payment from Citizens, Citizens claimed that the loss limit was $50 million in the aggregate, not per occurrence. Tiara filed suit against Marsh, alleging, inter alia, breach of contract, breach of fiduciary duty, and negligence. The trial court granted summary judgment for Marsh on all claims. The appeals affirmed with the exception of the negligence and breach of fiduciary claims, as to which it certified a question to the Supreme Court to determine whether the economic loss rule prohibits recovery, or whether an insurance broker falls within the professional services exception that would allow Tiara to proceed with the claims. The Court answered by holding that the application of the economic loss rule is limited to products liability cases. View "Tiara Condo. Ass'n, Inc. v. Marsh & McLennan Cos. " on Justia Law

Defendant was convicted of first-degree murder and sentenced to death. After his initial postconviction motion was denied, Petitioner filed an amended successive postconviction motion to vacate his judgments and sentence. Defendant filed a motion for discovery with regard his postconviction claim of newly discovered evidence, seeking production of a photograph card of an unidentified fingerprint found on the victim's check, which Defendant sought to compare with that of a deceased death row inmate. The postconviction court denied Defendant's motion for discovery and summarily denied his amended successive postconviction motion. The Supreme Court affirmed, holding (1) the postconviction court correctly summarily denied relief on the postconviction motion, as (i) Defendant's claim was time-barred, and furthermore, the record showed Defendant was not entitled to relief; (ii) Defendant was not entitled to a new trial based on newly discovered evidence; and (iii) Defendant was not deprived of his due process rights to present evidence on his challenge to Florida's lethal injection procedures. The Court also affirmed the circuit court's denial of Defendant's motion for discovery, as Defendant did not show his request would result in discovery of relevant or material evidence. View "Reed v. State" on Justia Law

In 1976, Defendant was convicted of the first-degree murders of his wife Eunice Zeigler and Charlie Mays and the second-degree murders of his in-laws, Perry and Virginia Edwards. In 2001, the trial court granted Defendant's motion for DNA testing for the purposes of clemency proceedings. After the testing was completed, Defendant filed a motion to vacate his sentences, arguing that the presence of Perry's blood on Mays' clothing corroborated his testimony that Mays was a perpetrator rather than a victim. The trial court denied the motion, and the Supreme Court affirmed. In 2009, Defendant filed a motion for postconviction DNA testing requesting further testing of the victims' clothing. Following an evidentiary hearing, the circuit court denied Defendant's motion. The Supreme Court affirmed, holding that Defendant had not met his burden of showing how the results of the DNA testing would give rise to a reasonable probability of a different outcome. View "Zeigler v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and was sentenced to death. The Supreme Court affirmed Defendant's conviction and sentence, holding (1) Defendant's claims regarding the constitutionality of certain aggravators and jury instructions were denied because Defendant provided no reasons that the Court should depart from its precedent upholding the constitutionality of these aggravators and instructions; (2) competent, substantial evidence supported Defendant's murder conviction; and (3) under the totality of the circumstances, Defendant's death sentence was proportional in relation to other death sentences the Court has upheld. View "Matthews v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. Defendant appealed, contending, among other things, that the trial court erred when it denied his motion to suppress his confession because, during his interrogation and before he confessed to the murder, he invoked his right to remain silent. The Supreme Court reversed and remanded for a new trial, holding (1) based on the totality of the circumstances, the police did not scrupulously honor Defendant's invocation of his right to remain silent; (2) there was not competent, substantial evidence to support the trial court's finding that Defendant's confession was voluntary; and (3) the State failed to establish that this error was harmless beyond a reasonable doubt. View "Deviney v. State" on Justia Law