Justia Florida Supreme Court Opinion Summaries

Defendant appealed his convictions for the first degree murders of three victims and his sentence of death. Defendant raised four issues on appeal: the trial court erred in denying his motion for judgment of acquittal; the trial court erred in finding the heinous, atrocious, or cruel aggravator for the murder of Ivory; the trial court erred in assessing the mental health mitigating evidence; and the death sentence was not proportionate. The court held that none of these claims warranted relief and affirmed the convictions and sentence of death. View "Heyne v. State of Florida" on Justia Law

Defendant appealed the denial of his postconviction motion filed under Florida Rule of Criminal Procedure 3.851 and petitioned the court for a writ of habeas corpus. The court addressed issues related to meaningful appellate review; ineffective assistance of counsel during the penalty phase; summarily denied claims; a motion to amend; and records requested. The court ultimately denied defendant's postconviction motion and his habeas petition. View "Tanzi v. State; Tanzi v. Tucker, etc." on Justia Law

Defendant was convicted of first degree murder, kidnapping, and aggravated battery. On appeal from the partial denial of postconviction relief, defendant claimed that the trial court erred in summarily denying his claim that counsel was ineffective for failing to object to evidence of possible blood stains outside the apartment and failing to present evidence to the jury that defendant's statement to law enforcement was involuntary. Defendant also alleged cumulative error. The court affirmed the trial court's denial of relief on these issues. View "Walker, II v. State of Florida" on Justia Law

Defendant appealed an order of the circuit court denying his motion to vacate his conviction of first degree murder and sentence of death filed under Florida Rule of Criminal Procedure 3.851 and petitioned the court for a writ of habeas corpus. The court rejected defendant's claim that the postconviction court improperly denied his motion to disqualify the judge and that the judge demonstrated bias by relying on extra-record information where defendant failed to demonstrate any bias; the postconviction court properly denied relief on defendant's several claims of ineffective assistance of counsel; defendant failed to demonstrate prejudice regarding his claim that the prosecutor made several erroneous remarks at trial and that the trial court improperly instructed the jury; the lower court correctly found that defendant's claim that he was innocent of the death penalty was waived because it was not raised on direct appeal; the lower court properly found that defendant's claim that his statement to the police was involuntary was procedurally barred because the issue was already considered and rejected by the court on appeal; and defendant's petition for habeas corpus was denied. View "Krawczuk v. State" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death. On appeal, defendant challenged the denial of his successive motion for postconviction relief pursuant to Florida Rule of Criminal Procedure 3.851. The court affirmed the circuit court order that summarily denied relief on all defendant's claims, holding that the recent decision from the United States Supreme Court in Martinez v. Ryan did not provide defendant with any basis for relief. View "Gore v. State" on Justia Law

Defendant was charged with possession of cocaine, possession of drug paraphernalia, and grand theft. Defendant entered a guilty plea and was sentenced to 18 months' imprisonment, which was the minimum sentence indicated on the Criminal Punishment Code sentencing scoresheet. At issue was whether the State was authorized under section 924.07, Florida Statutes, to appeal a sentence that was otherwise legal on the ground that the trial court improperly initiated a plea dialogue with a defendant without invitation of either party. The court held that the procedural error in disregarding the mandates of the habitual felony offender statute did not render defendant's sentence illegal or otherwise appealable by the State under section 924.07. For this reason, and because the court also concluded that the State was not authorized to appeal the sentence on the ground that the trial court improperly initiated a plea dialogue in this case, the court approved the result reached by the Fourth District. View "State v. McMahon" on Justia Law

Defendant was tried on three counts of armed robbery and three counts of false imprisonment with a weapon or firearm. At issue was the misapplication of the trial court and the First District of the procedure the court set forth in Melbourne v. State for eliminating discrimination during the exercise of peremptory challenges. In this case, the trial court erred in denying defense counsel's peremptory challenge to a female juror, notwithstanding the undisputed gender-neutral reason counsel proffered. The trial court mistakenly assessed defense counsel's reason as if it were assessing a challenge for cause and failed to perform the critical third step of the Melbourne procedure, which required an assessment of the genuineness of counsel's proffered reasons for the strike. Further, the trial court erroneously relieved the State of its burden to establish that the reason for the challenge was pretextual. The court concluded that the First District district perpetuated these errors and quashed the decision of the First District. View "Hayes v. State" on Justia Law

This case arose from a fatal automobile-truck collision. Petitioners, as personal representative of the estate of the deceased and other individuals, filed an action against Airgas, a foreign corporation, and the Airgas employee that drove the truck that struck the deceased. The district court certified the following question: "Where an individual, non-resident defendant commits negligent acts in Florida on behalf of his corporate employer, does the corporate shield doctrine operate as a bar to personal jurisdiction in Florida over the individual defendant?" The court answered the question in the negative and concluded that Airgas employees were subject to the personal jurisdiction of Florida courts pursuant to Florida Statute 48.193. View "Kitroser, etc., et al. v. Hurt, et al." on Justia Law

Petitioner entered a no contest plea to the charges of burglary of a dwelling, grand theft, and falsification of ownership to a pawnbroker. The court adjudicated her guilty of all three counts and sentenced her to five years imprisonment. However, the court suspended her sentence on the condition that she complete two years of community control followed by probation, as well as pay monetary restitution. Petitioner was subsequently charged with driving with a suspended license pursuant to section 322.34, Florida Statutes. After her arrest, petitioner paid the required restitution, and the DHSMV reinstated her license. However, petitioner still faced a charge of violation of probation based upon the charge of driving with a suspended license. The court held that the Fifth District correctly held that the State sufficiently established the knowledge requirement of the current version of section 322.34(2) because (1) the mailing of the written notice of suspension satisfied the notice requirement of section 322.251(1), and (2) the State proved that this was the address of petitioner at the time of the mailing. Accordingly, the court affirmed the judgment, disapproving Brown v. State and Haygood v. State to the extent that those decisions conflicted with the opinion of the court. View "Anderson v. State" on Justia Law

In an automobile and train collision case, the court considered the provisions of Florida law governing the selection of venue based on the residency of defendants. At issue was the limitation placed on the selection of venue - known as the joint residency rule - derived from Enfinger v. Baxley, which held that the selection of venue based on residency was limited to the county of residence shared by the individual defendant and the corporate defendant. Because Enfinger was predicated on a serious misinterpretation of the governing statutes, the court resolved the conflict by receding from Enfinger. The court concluded that the Florida courts should uniformly apply the plain language of the venue statues enacted by the Legislature, not the judicially created joint residency rule. Accordingly, the court quashed the decision of the Fourth District. View "Brown, et al. v. Nagelhout, et al." on Justia Law