Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of the first-degree murder of a high school band teacher. The trial court sentenced Defendant to death. The Supreme Court affirmed on appeal. Defendant later filed a petition for postconviction relief under Fla. R. Crim. P. 3.850, alleging, inter alia, that his trial counsel was ineffective for several reasons. After an evidentiary hearing, the circuit court denied relief. The Supreme Court affirmed the denial of Defendant's motion for postconviction relief, holding (1) the circuit court did not prejudicially err in finding that Defendant's counsel provided effective assistance; and (2) the circuit court did not prejudicially err in summarily denying the remainder of Defendant's claims. View "Foster v. State" on Justia Law

Pursuant to a plea of nolo contendere, Defendant was convicted of sex-related offenses and sentenced to forty-five years' imprisonment. Nearly eleven years after the sentence had been imposed, Defendant filed a motion to withdraw plea arguing that he was entitled to withdraw his plea because the trial court failed formally to accept his plea during the plea colloquy. The postconviction court ruled that the trial court's inadvertent failure to formally accept Defendant's plea did not entitle Defendant to withdraw his plea. The court of appeal affirmed, holding that Defendant was not entitled to withdraw his plea after he was sentenced absent a showing of manifest injustice or clear prejudice. The Supreme Court affirmed, holding that the actual sentencing of a defendant is a sufficient affirmative statement to the parties made in open court and on the record as to constitute formal acceptance of a plea under Fla. R. Crim. P. 3.172(g), and actual sentencing evidences the finality in the proceedings where the right to withdraw a plea is revoked. View "Campbell v. State" on Justia Law

In 1988, Defendant pleaded guilty to first-degree murder. Defendant was sentenced to death and to terms of imprisonment for related charges. The Supreme Court affirmed the convictions and sentence. Defendant subsequently filed a motion to vacate his conviction for first-degree murder and sentence of death, alleging that his standby counsel or the trial court sua sponte should have ordered a competency hearing before allowing him to plead guilty and that he may be insane at the time of execution. The circuit court denied the motion without an evidentiary hearing. The Supreme Court affirmed, holding that the circuit court did not err in summarily denying Defendant's motion for postconviction relief from his conviction and sentence for first-degree murder. View "Barnes v. State" on Justia Law

After a jury trial, Defendant was convicted of six counts of first-degree murder and one count each of abuse to a dead human body, armed burglary of a dwelling, conspiracy, and cruelty to an animal. The trial court imposed four death sentences, two life sentences, and additional terms for the noncapital crimes. Defendant subsequently filed a motion to vacate his convictions, which the postconviction court denied. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus, contending that his appellate counsel provided ineffective assistance. The Supreme Court affirmed the postconviction court's denial of Defendant's motion for postconviction and denied habeas corpus relief, holding (1) the postconviction court did not err in denying (i) thirteen of Defendant's claims of ineffective assistance of counsel, as Defendant did not demonstrate that he was prejudiced by any error made by trial counsel, and (ii) Defendant's claim that his death sentences were unconstitutional under Ring v. Arizona, as Defendant's claim based on Ring was procedurally barred and without merit; and (2) Defendant's habeas claim was without merit. View "Victorino v. State" on Justia Law

Petitioner was a juvenile charged as an adult with attempted first-degree murder with a deadly weapon. After the U.S. Supreme Court issued its decision in Graham v. Florida, Petitioner filed a motion to have a bond set. The trial court denied the motion. Petitioner filed a second petition for writ of habeas corpus, arguing (1) the Florida Constitution provides for pretrial release as a matter of right for a noncapital offense or an offense that does not carry the possibility of a life sentence, and (2) because Graham prohibits the State from sentencing him to life without an opportunity for parole, he was entitled to bond under the provisions of the State Constitution. The court of appeal denied the petition, concluding that Graham does not impact a juvenile defendant's entitlement to bond because the Florida Constitution considers only the classification of the offense, not a defendant's eventual sentence. The Supreme Court quashed the decision below, holding that juvenile offenders such as Petitioner were entitled to bond under the Florida Constitution because they cannot be charged with a crime punishable by life imprisonment under Florida's current statutory scheme and Graham. View "Treacy v. Lamberti" on Justia Law

This was the second time this case was before the Supreme Court. In the Court's previous decision, the Court quashed the court of appeal's decision, holding that the trial court should have granted Defendant's motion to suppress evidence obtained from a search of Defendant's truck, holding that law enforcement officers lacked probable cause where "the fact that a drug-detection dog has been trained and certified to detect narcotics, standing alone, is not sufficient to demonstrate the reliability of the dog." The U.S. Supreme Court reversed, holding that because the training records established the dog's reliability in detecting drugs in this case, and because Defendant failed to undermine that showing, the police officer had probable cause to search Defendant's truck. On remand, the Florida Supreme Court withdrew its prior opinion and approved of the court of appeal's decision in Harris I. View "Harris v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder and burglary. Defendant appealed, alleging that the trial court's failure to remove a prospective juror for cause resulted in a denial of his right to a fair and impartial jury as guaranteed by the state and federal constitutions. The court of appeal affirmed, concluding that the juror was competent to serve. The Supreme Court quashed the decision of the third district and remanded for a new trial, holding that the juror demonstrated during voir dire that she could not fulfill her role as a fair and impartial arbiter and thus should have been excused for cause. View "Matarranz v. State" on Justia Law

After a jury trial, Defendant was convicted of burglary of a dwelling with an assault or battery with a dangerous weapon, robbery with a weapon, and carjacking with a dangerous weapon. The court of appeal affirmed Defendant's convictions for burglary of a dwelling and carjacking but certified conflict on the issues of (1) whether Florida's burglary statute requires a structure to be suitable for habitation on the date of the offense for the structure to meet the definition of a dwelling, and (2) whether a defendant can be convicted of carjacking where the force used in the robbery on the inside of the building is separate from the taking of the vehicle on the outside of the building. The Supreme Court affirmed the court of appeal, holding (1) a structure undergoing substantial renovations constitutes a "dwelling" under the relevant statute; and (2) Defendant's actions constituted a carjacking under the relevant statute. View "Young v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder, two counts of robbery, and two counts of kidnapping. The trial court sentenced Defendant to concurrent sentences of death for both murders. The Supreme Court affirmed the convictions and sentences of death. Defendant subsequently filed a motion for postconviction relief, alleging that his trial counsel provided ineffective assistance. The postconviction court denied all of Defendant's claims. The Supreme Court affirmed the denial of relief and denied Defendant's petition for a writ of habeas corpus, holding (1) trial counsel did not provide constitutionally defective assistance; (2) Florida's death sentencing scheme is constitutional; and (3) Defendant's appellate counsel did not provide ineffective assistance. View "Jackson v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed the first-degree murder conviction and death sentence, holding (1) the trial court did not err in finding a cold, calculated and premeditated aggravator; (2) Defendant's death sentence was proportionate; (3) the penalty-phase jury instructions did not violate Caldwell v. Mississippi, and Ring v. Arizona did not require the reversal of Defendant's death sentence; (5) the trial court did not err in refusing to permit Defendant to present guilt-phase evidence of his mental condition at the time of the murder; and (6) competent, substantial evidence supported the verdict beyond a reasonable doubt. View "Brown v. State" on Justia Law