Justia Florida Supreme Court Opinion Summaries

Delta sought review of the First District's reversal of summary judgment voiding a tax deed and quieting title to certain real property in Delta. The court concluded that the First District improperly applied the law-of-the-case doctrine and that the validity of the tax deed in this case should be determined by applying Jones v. Flowers and Vosilla v. Rosado. The court further held that because the Clerk failed to take reasonable, additional steps to provide notice to Delta upon learning that the notice sent by certified mail was not successfully delivered, the tax deed was invalid. Therefore, the court quashed the First District's decision and remanded with instructions that the trial court's grant of summary judgment in favor of Delta be affirmed. View "Delta Property Mgmt., etc. v. Profile Investments, Inc., et al." on Justia Law

This case involved the application of Florida's Involuntary Civil Commitment of Sexually Violent Predators Act, 394.9135, Florida Statutes, commonly known as the Jimmy Ryce Act, to defendant, who had been detained by the State and awaiting a civil commitment trial pursuant to that Act since April 2002. The court held that (1) neither the Jimmy Ryce Act nor the Constitution entitled defendant to the treatment he sought as a noncommitted detainee; defendant failed to establish that the FCCC treatment program was constitutionally defective; and (3) because the delay in defendant's commitment trial had been made for tactical reasons at his own request, his detention did not result in a constitutional violation. View "Morel v. Wilkins, etc." on Justia Law

Defendant appealed the denial of his postconviction motion to vacate his convictions and sentences filed under Florida Rule of Criminal Procedure 3.851. Defendant's convictions included a conviction of first-degree murder for which the trial court imposed a sentence of death. Defendant also petitioned for a writ of habeas corpus. The court rejected all of defendant's claims and affirmed the postconviction court's denial of defendant's rule 3.851 motion and denied defendant's petition for writ of habeas corpus. View "Taylor v. State; Taylor v. Tucker" on Justia Law

Defendant was convicted of first degree murder based on the shooting death of his wife. On appeal, defendant raised eight issues: (1) whether the trial court erred in permitting evidence of his prior bad acts; (2) whether the trial court erred in finding that the murders were committed in a cold, calculated, and premeditated manner without pretense of moral or legal justification; (3) whether the jury's recommendation at the penalty phase was tainted by improper victim impact evidence; (4) whether the trial court erred in overruling his objections and allowing introduction of evidence of his extramarital sexual relationship; (5) whether the trial court erred in denying his motion for judgment of acquittal on the kidnapping charge; (6) whether the trial court erred in instructing the jury on the heinous, atrocious, or cruel aggravator; (7) whether his death sentence was proportional; (8) whether the trial court erred in sentencing him to death because section 921.141, Florida Statutes, unconstitutionally allowed the trial court to proceed without, among other things, a unanimous death recommendation from the jury in contravention of the Sixth Amendment. The State also raised two claims on cross-appeal: (1) whether the trial court erred in failing to find the heinous, atrocious, or cruel aggravator, and (2) whether the trial court erred in denying the State's motion in limine regarding the testimony of Dr. Elizabeth McMahon. The court addressed these claims and reviewed for sufficiency of the evidence to uphold the conviction and sentence, and affirmed the judgment. View "Kopsho v. State " on Justia Law

Defendant appealed his conviction for first degree murder and his death sentence. In his direct appeal, defendant raised twelve issues challenging the effectiveness of his trial counsel and various rulings and conclusions made by the trial court at both the guilt and sentencing phases, including an issue regarding the proportionality of the death sentence. Defendant also challenged the constitutionality of Florida's capital sentencing scheme. After reviewing the issues brought on appeal and conducting the court's own independent review of the sufficiency of the evidence, the court affirmed defendant's convictions for first degree murder, burglary with a battery while armed with a firearm, animal cruelty, grant theft of a motor vehicle, and grant theft of a firearm and the sentences imposed for these offenses. View "Ellerbee, Jr. v. State" on Justia Law

The facts in this case arose from an arrest after the driver failed a roadside sobriety test and then had her license suspended based on the refusal to submit to a breath test. The court was asked to answer two certified questions: (1) "Does a law enforcement officer's request that a driver submit to a breath, blood, or urine test, under circumstances in which the breath-alcohol test is the only required test, violate the implied consent provisions of section 316.1932(a)(A)(1)(a) such that the department may not suspend the driver's license for refusing to take any test?" and (2) "May a district court grant common law certiorari relief from a circuit court's opinion reviewing an administrative order when the circuit court applied precedent from another district court but the reviewing district court concludes that the precedent misinterprets clearly established statutory law?" The court answered the first certified question in the negative. The Second District properly found that there was no violation of the implied consent law under the circumstances of this case. Accordingly, the court approved the Second District's decision and disapproved the Fourth district's opinion in State Department of Highway Safety and Motor Vehicles v. Clark to the extent that it concluded to the contrary. The court answered the second question in the affirmative and held that a district court could exercise its discretion to grant certiorari review of a circuit court decision reviewing an administrative order, so long as the decision under review violated a clearly established principle of law resulting in a miscarriage of justice, even if the circuit court decision was based on precedent from another district.View "Nader v. FL Dept. of Highway Safety and Motor Vehicles, Et Al." on Justia Law

Defendant was found guilty of first-degree felony murder, second-degree murder, and aggravated child abuse. At issue was whether the merger doctrine precluded a first-degree felony-murder conviction predicated on a single act of aggravated child abuse that caused the child's death. Based upon legislative intent as evidenced by the plain language of the felony-murder statute, the court held that the merger doctrine did not preclude a felony-murder conviction predicated upon a single act of aggravated child abuse that caused the child's death. Accordingly, the court answered the certified question in the negative, receded from Brooks v. State to the extent that it held to the contrary, and quashed the First District's decision, View "State v. Sturdivant" on Justia Law

This case arose when defendant was arrested and charged in county court with the misdemeanor offenses of possessing marijuana, possessing drug paraphernalia, and driving under the influence. Defendant filed a motion to suppress all evidence obtained during the search that followed the stop, claiming that the stop was illegal because it was not based upon probable cause that she had committed a traffic infraction. At issue was the application of the fellow officer rule to testimony in a motion to suppress hearing where defendant was challenging the validity of the traffic stop. The court held that the fellow officer rule did not allow an officer who did not have firsthand knowledge of the traffic stop and was not involved in the investigation at the time to testify as to hearsay regarding what the initial officer who conducted the stop told him or her for the purpose of proving a violation of the traffic law so as to establish the validity of the initial stop. Therefore, the court disapproved of the Fourth district in Ferrer v. State and approved the decision of the Second District in Bowers v. State. View "State v. Bowers" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death for his role in the 1987 killing of a correctional officer. Defendant subsequently appealed the circuit court's summary denial of his second successive motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.851. Because defendant's claim originated from information that existed as early as this court's issuance of its direct-appeal decision in 1990, and because the juror affidavits at issue in this case related to matters that inhered in the verdict, the court affirmed the circuit court's denial of this claim as both untimely and based upon inadmissible evidence. View "Van Poyck v. State" on Justia Law

This case was before the court on appeal from a judgment of conviction of first degree murder and a sentence of death. The court held that the trial court properly limited the cross-examination of a State witness; the trial court did not abuse its discretion in overruling defense counsel's objection and denying a mistrial based upon the prosecution's statement; the trial court did not abuse its discretion in admitting the 47 shell casings into evidence along with the other evidence to which they related; the trial court properly declined to conduct a Frye hearing on tool-mark identification; the trial court did not err in accepting the State's explanation for exercising a peremptory strike to remove a minority juror; and the death sentence was proportionate where, in addition to murdering the victim, defendant also kidnapped her from her home and raped her. Accordingly, the convictions and sentences were affirmed. View "King v. State" on Justia Law