Justia Florida Supreme Court Opinion Summaries

Defendant shot and killed a convenience store clerk during a robbery and was subsequently tried and convicted of armed robbery and first degree murder. At issue was whether the facts supported the trail court's legal conclusion that defendant had established the first prong of the mental retardation standard, i.e. significantly subaverage general intellectual functioning. The court held that the circuit court erred as a matter of law in finding that defendant met the definition of mental retardation under Florida law and therefore vacated the circuit court's order granting defendant's postconviction motion. View "State v. Herring" on Justia Law

Defendant was convicted of two counts of first-degree murder for the stabbing deaths of his cousin's girlfriend and her four-year-old daughter. Defendant appealed his convictions and sentences of death. The court held that the trial court did not abuse its discretion in denying defendant's motion for mistrial and in finding no discovery violations. The court also held that there was no basis that would disqualify the jury from rendering a penalty recommendation. The court rejected defendant's challenge to the constitutionality of Florida's death sentencing scheme. The court further held that the record demonstrated that there was competent, substantial evidence to sustain defendant's convictions. The court finally held that based on the evidence set forth, the aggravators the trial court found, and the totality of the circumstances, defendant's death sentences were proportionate compared to other death sentences the court had upheld. Accordingly, the court affirmed the convictions and sentences. View "Knight v. State" on Justia Law

Defendant was convicted of the first-degree shooting murder of a deputy sheriff, the attempted murder of another deputy sheriff, and armed robbery. Defendant was sentenced to death. Both defendant and the State raised issues on appeal. The court held that the trial court did not abuse its discretion in admitting photographic evidence and a vial of blood; in admitting a bullet fragment into evidence; and in failing to instruct the jury that defendant was not guaranteed parole at or after 25 years. The court also held that, because defendant failed to demonstrate that any of his claims amounted to error, defendant's claim of cumulative error was denied. The court finally held that, when compared with other capital cases, the death sentence in defendant's case was proportionate. View "Armstrong v. State of Florida" on Justia Law

Twenty-six Florida counties and the Florida Association of Counties filed suit seeking a declaratory judgment that section 19 of the Laws of Florida (Act) was unconstitutional. The district court affirmed the trial court's decision and held that section 19 of the Act unconstitutionally shifted the responsibility to fund certain costs of court-appointed counsel from the state to the counties in violation of article V, section 14, of the Florida Constitution and that section 19 was unconstitutional based on the Legislature's failure to make the constitutionally required determination of an important state interest, as provided by article VII, section 18(a) of the constitution. The court agreed with the district court and the circuit court that the plain language of article V, section 14 provided that the state was responsible for funding the Offices of Criminal Conflict and Civil Regional Counsel (RCC), including the overhead costs outlined in subsection (c). The court held that, based on its determination that the district court correctly held that section 19 was unconstitutional under article V, section 14, the court concluded that it was unnecessary to address whether section 19 violated article VII, section 18(a) of the constitution. View "Lewis, et al. v. Leon County, et al." on Justia Law

Defendant appealed his conviction of first-degree murder and sentence of death. The court held that the trial court did not abuse its discretion in accepting defendant's request to waive the presentation of mitigation during the penalty phase where the trial court complied with the three-part procedure in Koon v. Dugger and complied with the Muhammad v. State requirements. The court also affirmed the trial courts finding of cold, calculated, and premeditated (CCP) and especially heinous, atrocious, or cruel (HAC) aggravators. The court court further held that because the trial court did not abuse its discretion, the court would not reweigh the trial court's assignment of weight. Therefore, the court held that defendant's death sentence was proportionate. The court finally held that a review of the record revealed that defendant's plea was made knowingly, intelligently and voluntarily. Therefore, the plea and conviction were properly entered. Further, the factual basis for the plea, which was confirmed by defense counsel and defendant, and was proven by the forensic evidence and defendant's confessions, provided competent, substantial evidence to support the conviction and sentence. View "Russ v. State of Florida" on Justia Law

This case arose when respondent, a resident of New York, filed a petition for administration asserting that he was entitled to be appointed personal representative of the estate of the decedent because he was the decedent's stepson and was nominated as personal representative in the will. At issue was whether an objection to the qualifications of a personal representative of an estate was barred by the three-month filing deadline set forth in section 733.212(3), Florida Statutes, a provision of the Florida Probate Code, when the objection was not filed within the statutory time frame. The court held that section 733.212(3) barred an objection to the qualifications of a personal representative, including an objection that the personal representative was never qualified to serve, if the objection filed under this statute, except where fraud, misrepresentation, or misconduct with regard to the qualifications was not apparent on the face of the petition or discovered within the statutory time frame. Accordingly, because fraud, misrepresentation, or misconduct was not alleged in relation to the objection to the personal representative in this case, the court approved the decision of the First District Court. The court also held that, to the extent that the decision of the Third District Court in Angelus v. Pass involved allegations of fraud or misrepresentation not revealed in the petition for administration, the court approved the result in Angelus. However, the court disapproved Angelus to the extent that it held section 733.212(3) did not bar objections that a personal representative was never qualified to serve. View "Hill v. Davis, Etc." on Justia Law

Defendant was convicted of trafficking in cocaine and sale or possession of cocaine within 1000 feet of a church. At issue was whether the trial judge's arbitrary policy of rounding up sentences constituted a due process violation that was fundamental error reviewable on appeal without contemporaneous objection. The court held that the sentence imposed was within the legal guidelines - it was above the minimum required by the scoresheet and below the statutory maximum, but the trial judge's stated policy "improperly extended" defendant's incarceration in an arbitrary manner. Therefore, because this policy of "rounding up" violated defendant's right to due process, the court quashed the decision and remanded with directions that the trial court be directed to enter a sentence at the bottom of the guidelines and consistent with the reasoning expressed. View "Cromartie v. State of Florida" on Justia Law

State Farm petitioned for review of the Third District's determination that the household exclusion in its policy issued to respondents was ambiguous and therefore could not be enforced to eliminate coverage for bodily injuries suffered by members of the household of a permissive-driver insured. The court held that the plain language of the household exclusion precluded coverage for bodily injuries suffered by members of the household of a permissive-driver insured, such as the parents in this case. Therefore, the court quashed the Third District's decision, approved Linehan v. Alkhabbaz, and remanded for further proceedings. View "State Farm Mutual Auto. Ins. Co. v. Menendez, et al." on Justia Law

Appellant, a prisoner under sentence of death, appealed the denial of his amended successive motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.851. Defendant raised numerous claims, including an Eighth Amendment challenge to the Florida Department of Correction's (DOC) lethal injection protocol, which replaced the first drug in its three-drug sequence, sodium thiopental, with another drug, pentobarbital sodium. The court held that, after reviewing the evidence and testimony, appellant had failed to satisfy the "heavy burden" that Florida's current lethal injection procedures, as implemented by the DOC, were constitutionally defective in violation of the Eighth Amendment. The court affirmed the circuit court's orders and vacated the temporary stay on execution. View "Valle v. State of Florida" on Justia Law

This case was before the court on the petition of Rosalie Whiley for a writ of quo warranto seeking an order directing the Governor of the State of Florida to demonstrate that he had not exceeded his authority, in part, by suspending rulemaking through Executive Order 11-01. The court granted relief and held that the Governor impermissibly suspended agency rulemaking to the extent that Executive Orders 11-01 and 11-72 included a requirement that the Office of Fiscal Accountability and Regulatory Reform (OFARR) must first permit an agency to engage in the rulemaking which had been delegated by the Florida Legislature. Absent an amendment to the Administrative Procedure Act, 5 U.S.C. 500 et seq., itself or other delegation of such authority to the Governor's office by the Florida Legislature, the Governor had overstepped his constitutional authority and violated the separation of powers. View "Whiley v. Hon. Rick Scott, etc." on Justia Law