Justia Florida Supreme Court Opinion Summaries

In 2007, the Legislature passed several statutes and included a provision in the 2007-2008 General Appropriations Act that exerted control over the setting of and appropriating for the expenditure of tuition and fees for the Florida university system. Petitioners challenged these statutes as unconstitutional, contending that the 2002 constitutional amendment creating the Board of Governors transferred the authority over tuition and fees to the Board, thus divesting the Legislature of any power over these funds. The trial court granted summary judgment in favor of the Legislature, and the court of appeal affirmed. The Supreme Court affirmed, holding that the challenged statutes by which the Legislature exercised control over the funds was facially constitutional, as (1) the constitutional source of the Legislature's control over the setting of and appropriating for the expenditure of tuition and fees derives from its power under Fla. Const. art. VII, 1(c) and (d) to raise revenue and appropriate for the expenditure of state funds; and (2) the language of the 2002 amendment is devoid of any indication of an intent to transfer this power to the Board. View "Graham v. Haridopolos" on Justia Law

Defendant was convicted of first-degree murder and was sentenced to death. The Supreme Court affirmed Defendant's sentence. Defendant filed a postconviction motion alleging ineffective assistance of counsel. The postconviction court denied the motion after an evidentiary hearing. Defendant appealed and also filed a habeas corpus petition. The Supreme Court affirmed the trial court's denial of Defendant's postconviction motion and denied his habeas petition, holding (1) Defendant did not establish that he received ineffective assistance of counsel, and therefore, his postconviction motion was correctly denied; (2) cumulative error did not deprive Defendant of a fair trial; (2) Defendant's sentence did not constitute cruel and unusual punishment; (3) Florida death penalty statute is not unconstitutional as applied to Defendant; and (4) counsel was not ineffective for failing to allege that Florida's capital sentencing statute is unconstitutional on its face and as applied to Defendant. View "Merck v. State" on Justia Law

In 2004, Defendant, a general contractor, subcontracted with Plaintiff, who was unlicensed under Florida law at the time, to perform work on a parking garage. After a dispute, Plaintiff sued Defendant for breach of contract. Defendant counterclaimed for breach of contract. During litigation, Defendant argued that because Plaintiff was unlicensed, its breach of contract claim was barred under Fla. Stat. 489.128, which provides that contracts entered into by an unlicensed contractor shall be unenforceable. Plaintiff countered that Defendant was also barred from enforcing the contract because the parties were in pari delicto based on Defendant's alleged knowledge of Plaintiff's unlicensed status. The trial court ruled against Plaintiff, holding that the common law defense of in pari delicto was unavailable under section 498.128. The fifth district court of appeal affirmed. The Supreme Court affirmed, holding that a party's knowledge that a contractor or subcontractor does not hold the state-required license to perform the construction work of the contract is legally insufficient to establish the defense that the parites stand in pari delicto. In so holding, the Court expressly disapproved the third district court of appeals' decision in Austin Building Co. v. Rago, Ltd., which directly conflicted with the fifth district's decision. View "Earth Trades, Inc. v. T&G Corp." on Justia Law

At issue in this case was the constitutionality of certain provisions of chapter 2011-68, Laws of Florida, which converted the Florida Retirement System (FRS) from noncontributory by employees to contributory, required all current FRS members to contribute three percent of their salaries to the retirement system, and eliminated the retirement cost-of-living adjustment for creditable service after the effective date of the act. The circuit court held that the challenged amendments were unconstitutional, where the amendments violated three provisions of the Florida Constitution, and ordered Appellants - the governor, state board of administration, and the secretary of the department of management services - to reimburse all funds deducted or withheld pursuant to chapter 2011-68 from the compensation or cost-of-living adjustments of employees who were members of the FRS prior to the effective date of the act. The Supreme Court reversed, holding that the legislature did not violate the Florida Constitution in enacting the challenged provisions of chapter 2011-68. View "Scott v. Williams" on Justia Law

Plaintiff, a resident of Arizona, sued Defendant, a foreign corporation that operates in Florida, after he contracted to buy an aircraft from Defendant but Defendant failed to deliver the aircraft. The U.S. district court applied Florida with respect to some of Plaintiff's claims and applied Arizona law to the remainder of the claims. The court also denied Defendant's motion for attorney's fees under the Florida Deceptive and Unfair Trade Practices Act (FDUTPA). On appeal, the Eleventh Circuit certified several questions to the Florida Supreme Court. The Court answered (1) because Plaintiff invoked FDUTPA by filing an action asserting a claim seeking recovery under FDUTPA in which Defendant ultimately prevailed, Defendant was entitled to attorney's fees under FDUPTA; (2) Defendant was entitled to fees for only the period of litigation until the federal district court held that FDUPTA did not apply to Plaintiff's claim; (3) Florida's offer of judgment statute does not apply to cases that seek both equitable relief and damages and in which Defendant has served an offer of judgment that seeks release of all claims; and (4) even if Florida's offer of judgment statute applied in this case, Defendant would not be entitled to attorney's fees under that section. View "Diamond Aircraft Indus., Inc. v. Horowitch" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended a death sentence. Following a Spencer hearing, the trial court sentenced Defendant to death upon determining that the State had proven beyond a reasonable doubt the existence of several statutory aggravators. The Supreme Court affirmed the conviction and sentence, holding (1) the evidence presented at trial was sufficient to support the first-degree murder conviction; (2) under the totality of the circumstances, the death sentence in this case was proportionate; (3) Florida's protocol for execution by lethal injection is constitutional; and (4) Florida's capital sentencing process is constitutional. View "Kocaker v. State" on Justia Law

Plaintiff filed a medical malpractice action against a dentist (Dentist) and his dental practice, alleging that Dentist's failure to diagnose and treat his dental conditions resulted in a bone infection and a worsening of his dental problems, which caused severe and permanent physical and emotional damage. In preparation for trial, there was an ex parte predeposition conference conducted between Plaintiff's nonparty treating physician and counsel provided by Defendant's insurance company. Plaintiff contended that the ex parte meeting violated the State's physician-patient confidentiality statute as delineated in Fla. Stat. 456.057(8). The Supreme Court held that section 456.057 prohibits such meetings and quashed the decision of the Fourth District holding otherwise. In particular, the Court held that an ex parte meeting such as the one attempted here is prohibited irrespective of whether the attorney and physician claim they will discuss only non-privileged matters. View "Hasan v. Garvar" on Justia Law

Defendant was originally convicted in 1981 for murder and sentenced to death. After a series of appeals and postconviction motions, Defendant filed a successive motion to vacate his sentence. Specifically, Defendant asserted that he was mentally retarded pursuant to Atkins v. Virginia. The trial court held an evidentiary hearing on Defendant's motion in 2009. The court denied relief, determining that Defendant could not meet the first prong of the mental retardation standard to establish his mental retardation. The Supreme Court affirmed, holding that there was competent, substantial evidence to support the court's finding that Defendant was not mentally retarded. View "Hall v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder, one count of burglary with assault or battery while armed, and one count of criminal mischief. The trial court imposed death sentences for both murders. The trial court subsequently denied Defendant's motion for postconviction relief. Defendant appealed the trial court's denial of his motion and petitioned the Supreme Court for a writ of habeas corpus. The Court affirmed the denial of Defendant's postconviction motion and denied his habeas petition, holding, among other things, that (1) Defendant's trial counsel did not provide ineffective assistance during the guilt phase or the penalty phase; (2) the State did not violate Brady v. Maryland by withholding evidence; (3) trial counsel was not operating under an actual conflict of interest due to counsel's workload; (4) the trial court did not err in denying several of Defendant's requests for additional public records; and (5) Defendant was not entitled to relief on any of the claims he raised in his habeas petition. View "Dennis v. State" on Justia Law

Defendants pled nolo contendere to charges of violating the sound standards of Fla. Stat. 316.3045(1)(a), reserving the right to appeal the constitutionality of the statute. Defendants subsequently appealed, arguing that the statute's "plainly audible" standard was constitutionally vague, overbroad, invited arbitrary enforcement, and impinged on their free speech rights. Bound by the Second District's decision in Easy Way of Lee County v. Lee County, the circuit court reversed. On appeal, the Second District denied the State's petition for certiorari relief, holding (1) the "plainly audible" standard of noise ordinance was unconstitutional, and (2) section 316.3045(3) was an unconstitutional content-based restriction because it contained an exemption for vehicles used for business and political purposes that use sound-making devices in the normal course of operations. The Supreme Court (1) affirmed the Second District's declaration that section 316.3045(1)(a) was invalid because it was an unreasonable restriction on the freedom of expression; (2) held that the statute was unconstitutionally overbroad, but not unconstitutionally vague; and (3) found that section 316.3045(3) was not severable from the remainder of the statute. View "State v. Catalano" on Justia Law