Justia Florida Supreme Court Opinion Summaries
Articles Posted in Florida Supreme Court
Garcia v. Andonie
This case was before the Supreme Court on a property appraiser's appeal of the court of appeal's decision affirming a circuit court's grant of an ad valorem homestead tax exemption to David and Ana Andonie (the taxpayers) and declaration that a portion of Fla. Stat. 196.031(1) was invalid and unenforceable because the statutory provision limited the class of property owners otherwise eligible for ad valorem tax relief under Fla. Const. art. VII, 6(a). The Court affirmed the decision of the court of appeal to the extent it was consistent with its holding here, holding (1) the plain language of article VII, section 6(a) permits every owner of Florida real property to apply for and receive ad valorem tax relief where it is sufficiently demonstrated that the owner has maintained on that property the permanent residence of another legally or naturally dependent on the owner; and (2) the property appraiser here failed to sufficiently preserve for appellate review any argument regarding the sufficiency of the evidence introduced in the circuit court below, and the record sufficiently demonstrated that the taxpayers maintained on their property the permanent residence of their minor children, each of whom was legally and naturally dependent on the taxpayers. View "Garcia v. Andonie" on Justia Law
Reynolds v. Tucker
After a jury trial, Petitioner was convicted of first-degree murder, second-degree murder, and burglary of a dwelling during which a battery upon the victims was committed while Petitioner was armed with a weapon. The trial court sentenced Petitioner to death for the first-degree murder convictions. Petitioner subsequently filed a motion to vacate his convictions of first-degree murder and sentences of death under Fla. R. Crim. P. 3.851. The circuit court denied the motion. Petitioner appealed and petitioned the Supreme Court for a writ of habeas corpus. The Court affirmed the denial of the Rule 3.851 motion, and denied Petitioner's petition for a writ of habeas corpus, concluding that no reversible error occurred and that defense counsel did not perform ineffectively. View "Reynolds v. Tucker" on Justia Law
Gill v. State
Appellant was a prisoner under sentence of death. After the Supreme Court affirmed Appellant's death sentence on direct appeal. D. Todd Doss was appointed as counsel for Appellant for Appellant's postconviction proceedings. Thereafter, Appellant sought to discharge Doss as postconviction counsel and waive the postconviction proceedings. The circuit court found Appellant competent and issued an order discharging Doss and dismissing the proceedings. Doss, on behalf of Appellant, appealed. The Supreme Court affirmed, holding (1) Appellant was afforded constitutionally adequate competency, waiver of postconviction, and discharge of counsel proceedings; and (2) the circuit court did nor err in finding Appellant competent to waive postconviction proceedings and to discharge counsel. View "Gill v. State" on Justia Law
Bd. Of Trs. of Internal Improvement Trust Fund v. Am. Educ. Enters., LLC
In this contract dispute, Respondent filed an action against Petitioner, claiming negligent misrepresentation, fraud in the inducement, unjust enrichment, and reformation of the contract. During discovery, Petitioner propounded to Respondent a request for the production of documents, seeking, inter alia, corporate financial documents, tax returns, budgets, and auditor's reports. Respondent objected to the request as overbroad, unduly burdensome, and irrelevant. Petitioner, in turn, moved to compel Respondent to provide the requested documents. The trial court granted Petitioner's motion and ordered Respondent to produce the requested items. Respondent petitioned the court of appeal for a writ of certiorari. The court of appeal quashed the order compelling production, holding that the order of the trial court compelling production was overbroad. The Supreme Court quashed the decision of the court of appeals, holding (1) the basis stated for certiorari relief was incorrect and in express conflict with numerous Florida decisions; and (2) because the requested information was relevant to the disputed issues and Respondent had not demonstrated irreparable harm through its disclosure, the information was discoverable. View "Bd. Of Trs. of Internal Improvement Trust Fund v. Am. Educ. Enters., LLC" on Justia Law
Posted in:
Contracts, Florida Supreme Court
Oyola v. State
Appellant was convicted of first-degree murder, false imprisonment as a lesser included offense of kidnapping, armed robbery with a deadly weapon, and grand theft of a motor vehicle. A jury recommended a sentence of death. The trial court accepted that recommendation and sentenced Appellant to death. The Supreme Court affirmed the findings and underlying judgment of guilty in the trial court but reversed and remanded for the limited purpose of requiring the trial court to perform a new sentencing evaluation because the analysis of the mitigating circumstances in the trial court's sentencing order did not meet the requirements articulated in Campbell v. State. View "Oyola v. State" on Justia Law
Martin v. State
After a jury trial, Appellant was convicted of first-degree murder and armed robbery and sentenced to death. The Supreme Court affirmed Appellant's convictions and sentence, holding (1) Appellant's statement to police was properly admitted into evidence, and police did not violate the Fifth Amendment in obtaining the statement; (2) Appellant's confession was voluntary, and contrary to Appellant's contention, the confession was not coerced by detectives; (3) the trial court did not err in finding the aggravating factor of cold, calculated, and premeditated to be established in Appellant's capital murder prosecution; (4) the trial court did not err in finding that Appellant did not prove the mitigating factors of emotional abuse, sexual abuse, and remorse; (5) the trial court did not overlook any material evidence in considering the aggravating and mitigating factors; (6) Appellant's constitutional challenge to Florida's death sentencing scheme was without merit; (7) Appellant's sentence of death was proportionate; and (8) there was sufficient evidence to support Appellant's convictions. View "Martin v. State" on Justia Law
Hopkins v. State
The State charged Defendant, who at the time was detained at a juvenile detention center, with one count of battery by detainee in violation of Fla. Stat. 784.03 and 784.082. Defendant moved to dismiss the charge, contending that a juvenile could not be lawfully charged with battery by detainee while detained in a juvenile detention facility. The trial court dismissed the charge based on its belief that it was bound to follow the first district court of appeal's decision in T.C. v. State, which held that the battery by detainee offense was inapplicable to juveniles held in juvenile facilities. The fourth district court of appeals reversed, noting that in the past it and the fifth district had affirmed a trial court order adjudicating a juvenile guilty of battery upon a fellow detainee. The Supreme Court affirmed, holding that a juvenile detention center qualifies as a "detention facility" for purposes of section 784.082, and thereby disapproving the first district's decision in T.C. View "Hopkins v. State" on Justia Law
Douglas v. Tucker
Petitioner was convicted of the 1999 sexual battery and first-degree murder of an eighteen-year-old and sentenced to death. The Supreme Court affirmed his convictions and sentences. Petitioner subsequently appealed the denial of his motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851 and simultaneously petitioned for a writ of habeas corpus. The Supreme Court affirmed the postconviction court's denial of relief and denied Petitioner's habeas petition, holding (1) Defendant failed to carry his burden of demonstrating he was prejudiced by trial counsel's deficient performance in preparation for the penalty phase; (2) Rule 3.851, which imposes a one-year time limit for filing motions for postconviction relief, is not unconstitutional; (3) Florida's capital sentencing statute is not unconstitutional; and (4) certain omissions by his appellate counsel on direct appeal did not constitute ineffective assistance of appellate counsel.
View "Douglas v. Tucker" on Justia Law
Leggett v. State
Defendant was charged with second-degree murder and was convicted as charged. The court of appeal affirmed. Defendant subsequently petitioned for writ of habeas corpus, arguing that his appellate counsel was ineffective for failing to raise a claim of fundamental error when the jury was instructed on manslaughter by intentional act as a lesser included offense. The third district court of appeal certified conflict with the decision of the first district court of appeal in Montgomery v. State. The Supreme Court stayed proceedings pending disposition of Montgomery. In Montgomery, the Court held that the use of the then-standard jury instruction on the lesser included offense of manslaughter by act constituted fundamental error in Montgomery's case because the instruction erroneously required the jury to find that the defendant intentionally caused the death of the victim. After the Court lifted the stay in the instant case, the Court quashed the decision under review and remanded the matter to the court of appeal for reconsideration upon application of its decision in Montgomery. View "Leggett v. State" on Justia Law
Altersberger v. State
Defendant Joshua Lee Altersberger pled guilty to the first-degree murder of Florida Highway Patrol Sergeant Nick Sottile. The jury found two aggravating circumstances beyond a reasonable doubt: the murder was committed in a cold calculated, and premeditated manner; and the victim was a law enforcement officer engaged in the lawful performance of his official duties. The trial court followed the jury's recommendation and sentenced Defendant to death. Defendant appealed. The Supreme Court affirmed Defendant's conviction and sentence, holding (1) the trial court did not err in its finding that Sergeant Sottile's murder was cold, calculated, and premeditated; (2) Defendant's plea was knowingly, intelligently, and voluntarily entered into; and (3) the death penalty was proportionate in this case. View "Altersberger v. State" on Justia Law