Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first-degree murder, kidnapping, and robbery. The trial court sentenced Defendant to death for the first-degree murder. The Supreme Court affirmed the convictions and sentences, holding, among other things, that the trial court did not err by (1) striking jurors based on hardship; (2) prohibiting Defendant from presenting testimony relating to the victim's inclination to pick up men at a park and bring them home; (3) limiting cross-examination of a jailhouse informant; (4) giving a voluntary intoxication instruction; (5) denying Defendant's motion to suppress his confession to the police and items found pursuant to the search of his duffel bag; (6) admitting autopsy photographs into evidence; and (7) denying Defendant's motion for acquittal. In addition, the Court found there was sufficient evidence to sustain Defendant's conviction for first-dgree murder, the death sentence in this case was proportionate, and Florida's death penalty sentence was constitutional. View "Patrick v. State" on Justia Law

A jury found Defendant guilty of nine counts of first-degree murder. The trial court imposed a death sentence for each of the first-degree murder counts. The convictions and death sentences were affirmed on appeal, and Defendant's subsequent motion for postconviction relief and petition for writ of habeas corpus were denied. The Governor signed a death warrant for Defendant, and the execution was set for December 11, 2012. Defendant filed a successive motion for postconviction relief, which the circuit court denied. The Supreme Court affirmed, holding that the circuit court did not err in (1) denying relief on Defendant's constitutional challenge to Florida's lethal injection protocol; (2) denying Defendant's public records requests; (3) denying Defendant's claim that he was incompetent to stand trial as procedurally barred; (4) denying relief on Defendant's claim that he was denied a full and fair clemency proceeding; and (5) denying Defendant's claim that executing him after the twenty-four years he spent on death row constituted cruel and unusual punishment. View "Pardo v. State" on Justia Law

Defendant pled guilty to twelve criminal counts related to the attempted kidnapping and shooting of two women who were sitting in a car. One of the women died as a result of the injuries she sustained when Defendant attempted to escape and crashed the car into a tree. On direct appeal, the Supreme Court affirmed Defendant's convictions but vacated his death sentence and remanded for a new penalty phase in light of the trial court's failure to consider all of the available mitigation. At the conclusion of the new penalty phase, Defendant was once against sentenced to death. The Supreme Court affirmed. Defendant subsequently filed a motion for postconviction relief, raising eleven allegations of error. The trial court denied all claims for relief. In addition to his appeal, Defendant also filed a petition for writ of habeas corpus, raising four claims. The Supreme Court (1) affirmed the trial court's denial of postconviction relief; and (2) denied Defendant's petition for habeas corpus relief. View "Farr v. State" on Justia Law

Petitioner, who was born in Nicaragua and entered the United States as a child, pleaded guilty to sale of a controlled substance, a second degree felony, in 2001. Following the U.S. Supreme Court's decision in Padilla v. Kentucky in 2010, Petitioner filed a postconviction motion alleging that his counsel failed to advise him that deportation was mandatory for the offense to which he pled guilty and that he would not have pled guilty if he had known that it would mandate his deportation without recourse. The circuit court denied Petitioner's motion on the basis that the immigration consequences warning included in the plea colloquy pursuant to Fla. R. Crim. P. 3.172(c)(8) precluded Petitioner from establishing the requisite prejudice under Strickland v. Washington. The Third District Court of Appeal upheld the denial of Petitioner's postconviction motion and then certified questions of law to the Florida Supreme Court. The Supreme Court answered (1) the immigration warning in Rule 3.172(c)(8) does not bar immigration-based ineffective assistance of counsel claims based on Padilla; and (2) however, the ruling in Padilla does not apply retroactively. Therefore, the Court approved of the Third District's decision upholding the denial of Petitioner's postconviction motion. View "Hernandez v. State" on Justia Law

The trial court entered a directed verdict against Plaintiff on her rear-end collision case against Defendant on the basis that she could not overcome the presumption of negligence that attached to her as the rear driver in this case. The court of appeal affirmed. The Supreme Court quashed the decision and remanded, holding that the evidence was sufficient for a jury to conclude that the rear driver's presumed negligence was not the sole proximate cause of the collision, and thus, under the Court's holding in Birge v. Charron, a directed verdict should not have been entered against Plaintiff on the basis of the rear-end presumption. View "Cevallos v. Rideout" on Justia Law

Plaintiff was a passenger on a motorcycle that flipped over when the driver of the motorcycle collided with the rear of an automobile driven by Defendant. The trial court granted summary judgment in favor of Defendant on the basis that Plaintiff could not rebut the presumption of negligence that attached to the driver of the motorcycle as the rear driver in a rear-end collision case. The court of appeal reversed, concluding that Plaintiff produced evidence from which a jury could find that Defendant was negligent and at least comparatively at fault in causing the collision. This certified conflict involved the interaction of Florida's comparative negligence system of tort recovery and a rebuttable presumption that has been imposed by courts in rear-end motor vehicle collision cases. The Supreme Court approved of the court of appeal's decision, holding that because tort recovery in Florida is governed by the principles of comparative negligence, the presumption that a rear driver's negligence is the sole cause of a rear-end automobile collision can be rebutted and its legal effect dissipated by the production of evidence from which a jury could conclude that the front driver was negligent in the operation of his or her vehicle. View "Birge v. Charron" on Justia Law

In this negligence action, the Supreme Court considered whether an employee who claims the benefit of sovereign immunity pursuant to Fla. Stat. 768.28(9), which entitles that employee not to be held personally liable in tort or named as a party defendant for acts within the scope of his or her employment, may obtain interlocutory review of an adverse trial court ruling where the question turns on an issue of law. The court of appeal declined to exercise certiorari review over a trial court's order denying summary judgment based on such a claim of individual immunity pursuant to section 768.28(9)(a). The Supreme Court quashed the court of appeal's decision and held (1) a claim of individual immunity from suit under section 768.28(9)(a) should be appealable as a non-final order under Fla. R. App. P. 9.130, obviating the necessity of determining whether common law certiorari would alternatively be available; and (2) the employee in this case was entitled to the individual immunity provided in section 768.28(9)(a). View "Keck v. Eminisor" on Justia Law

Appellant appealed from a judgment of conviction of first-degree murder and a sentence of death for the killing of Andrea Boyer, as well as a conviction for sexual battery by use of actual physical force likely to cause serious personal injury. The Supreme Court reversed the convictions, vacated the sentence of death, and remanded for a new trial, holding that reversible error occurred in the guilt phase of the trial, when the State introduced a lengthy videotape of Appellant's custodial interrogation in which the investigating officers repeatedly expressed their personal opinions about Appellant's guilt and the victim's character and family life. View "Jackson v. State" on Justia Law

The issue in this case was whether an appellate court should review a non-final order denying a claim of sovereign immunity by Citizens Property Insurance Corporation (Citizens), a state-created entity that provides property insurance, in a bad faith action stemming from the entity's handling of a property damage claim. The issue arose in the context of the broader question of when appellate courts should use common law writs to review non-final orders involving claims of immunity prior to the entry of a final judgment and when the Supreme Court should expand the list of non-final appealable orders. While the Court did not resolve the broader issue in this case, it determined that Citizens' claim of immunity was not reviewable by the appellate courts either through the writ of certiorari or the writ of prohibition, and the Court declined to expand the list of non-final orders reviewable on appeal to include the discrete legal issue presented in this case. View "Citizens Prop. Ins. Corp. v. San Perdido Ass'n, Inc." on Justia Law

Appellant appealed his first-degree murder conviction and sentence of death for the killing of Quatisha Maycock, as well as his convictions and sentences for related offenses. The Supreme Court affirmed Appellant's convictions and sentences, holding, among other things, (1) the trial court did not err in denying Appellant's motion to suppress the statements he made to police officers, all post arrest / custody observations of Appellant made by police officers, and evidence seized from Appellant; (2) the trial court did not err in denying Appellant's two motions to disqualify; (3) the prosecutor's comments during closing argument and made during the State's penalty phase closing argument did not rise to the level of fundamental error; (4) the evidence introduced at trial was sufficient to support Appellant's convictions for burglary, child neglect, and attempted escape; (5) The trial court did not err by requiring Appellant to argue all of his nonstatutory mitigating evidence as a single mitigating factor; (6) the trial court did not err by allowing the State to introduce at Appellant's penalty phase trial evidence of his prior violent felony convictions; and (7) Appellant's sentence was proportionate to death sentences that the Court has upheld in other cases. View "Braddy v. State" on Justia Law