Justia Florida Supreme Court Opinion Summaries

Defendant, who was 22 years old at the time of the crime, was convicted of first degree murder, attempted armed robbery, and aggravated battery due to this role in the robbery of a coin laundry, which resulted in the shooting death of the victim. Defendant appealed his first-degree murder conviction and sentence of death. The court affirmed defendant's conviction after addressing his issues of error but vacated his death sentence because the court concluded that imposing a sentence of death would not be a proportionate punishment under the circumstances of the case. Accordingly, the court remanded for imposition of a sentence of life imprisonment without the possibility of parole. View "Scott v. State" on Justia Law

Defendant appealed an order of the circuit court denying his amended motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.850 where he challenged his conviction of first degree murder and sentence of death and where he petitioned the court for writ of habeas corpus. Defendant raised twelve claims in his appeal from the denial of his rule 3.850 motion and also raised three claims in his petition for writ of habeas corpus. The court held that defendant's motion for postconviction relief was governed by rule 3.850 and his amended motion related back to the date of his original filing. With the single exception concerning this procedural claim, the court affirmed the postconviction court's denial of rule 3.850 and denied habeas relief. View "Lukehart v. State; Lukehart v. Buss" on Justia Law

Defendant pleaded guilty to burglary of a conveyance, grand theft of a quantity of mechanic's tools, and dealing in stolen property. Neither defendant or his counsel received notice that the State intended that he be sentenced as a habitual felony offender ("HFO") until, at the sentencing hearing, the State orally suggested that he qualified as an HFO. Defendant was then sentenced to concurrent terms of imprisonment and ordered to pay restitution to the victims. At issue was whether defendant's motion pursuant to Florida Rule of Criminal Procedure 3.800(b), claiming as sentencing errors the habitualization of the sentences without notice and insufficient evidence to support the amount of restitution ordered, properly preserved such errors. The court held that when, as in this instance, there was a clear sentencing error that affected the ultimate sanction imposed, it was cognizable under Rule 3.800(b). Accordingly, the court quashed that portion of the Second District's decision that reversed the trial court's order removing the HFO designation from defendant's sentence. The court held that the error complained of regarding the restitution order was not a sentencing error, but was one based on the sufficiency of the evidence that required a factual determination. Accordingly, it was not recognizable under Rule 3.800(b). View "Mapp v. State" on Justia Law

Respondent filed a complaint against petitioner, alleging the negligence of certain residents, fellows, and nurses at Jackson Memorial Hospital where her newborn son contracted a severe bacterial infection and subsequently died. At issue was whether, under section 768.28(7), Florida Statutes, the timing of respondent's service of process on the Florida Department of Financial Services ("DFS") was fatal to her negligence action. The court expressly rejected the argument that service of process on DFS was a condition precedent to respondent's cause of action and that proving service of process was an element of her burden of proof. Therefore, the court held that DFS was not a party to the cause of action and petitioner failed to demonstrate prejudice. The court concluded that the timing of respondent's service was not fatal to her negligence claim against petitioner and affirmed the trial court's denial of petitioner's motion for directed verdict. View "The Public Health Trust Of Miami-Dade County, Etc. v. Acanda" on Justia Law

Defendant was convicted of grand theft and robbery with a firearm. At issue was whether defendant's dual convictions violated the prohibition against double jeopardy under paragraph (b) of Fla. Stat. 775.021(4)(b). The court held that subsection (b)(2) was inapplicable where a comparison of the elements of the crimes in this case demonstrated that each offense required an element of proof that the other did not. The court also held that subsection (b)(3) was also inapplicable because neither offense was wholly subsumed by the other and therefore, neither was a necessarily included offense of the other. Accordingly the court affirmed the convictions. View "McKinney v. State" on Justia Law

Defendant appealed his convictions for first degree murder and sentences of death. The most critical and dispositive issue in this case involved the denial of a motion to suppress statements that defendant contended were improperly obtained after police administered a Miranda warning, which defendant asserted was materially deficient because police failed to properly advise him that he had the right to counsel both before and during the custodial interrogation. The court concluded that the Miranda warnings reasonably conveyed to defendant his right to counsel because, given the context in which the police administered the warnings, the warnings provided a clear, understandable instruction that defendant had the right to counsel both before and during a custodial interrogation. Therefore,the court held that in light of Florida v. Powell, the court found that the Miranda warnings the police administered to defendant were sufficient. The court also rejected all other claims raised by defendant on appeal. Accordingly, the court affirmed defendants convictions and sentences. View "Rigterink v. State" on Justia Law

Defendant was convicted of first degree murder of his estranged wife, the attempted first degree murder of her boyfriend, the armed kidnapping of his stepdaughter, and armed burglary. At issue was whether the prosecutor's improper statements during closing arguments entitled defendant to a new trial; whether juror misconduct entitled defendant to a new penalty phase; whether the trial court erred in finding the prior violent felony aggravator; whether defendant's death sentence was unconstitutional because the aggravating circumstances were not alleged in the charging document; whether the trial court erred in finding the murder was heinous, atrocious, or cruel; whether the trial court erred in finding the murder cold, calculated, and premeditated; and whether defendant's death sentence was not proportionate. Upon review of the record, the court held that competent, substantial evidence existed to support defendant's murder conviction on either theory of first degree murder, as well as his convictions for attempted first degree murder, armed kidnapping, and armed burglary of a dwelling. Accordingly, the court affirmed the convictions and sentences. View "Pham v. State" on Justia Law

Defendant was convicted for possession of a firearm by a felon and sentenced to ten years in prison. At issue was the scope of the pre-interrogation warnings required by the Fifth Amendment of the United States, as described in Miranda v. Arizona, and by article I, section 9 of the Florida Constitution, as described in Traylor v. State. The court held that, in light of the decision of the Supreme Court, the Miranda warnings at issue in this case sufficiently advised defendant of his rights as required by the Fifth Amendment and article I, section 9 of the Florida Constitution. Therefore, the court quashed the decision of the Second District and remanded the case to the district court for further proceedings. View "State v. Powell" on Justia Law

Appellant was convicted and sentenced to death in 1986 for the murder of a certain individual and sentenced to death on direct appeal. This appeal followed from the denial of postconviction relief alleging ineffective assistance of counsel in the second penalty-phase proceeding. At issue was whether appellant had ineffective assistance of penalty-phase counsel for failing to investigate, prepare, and present mitigating evidence and in failing to object to improper remarks made by the prosecutor in closing argument. The court held that, based on a review of the evidentiary hearings and the new penalty-phase trial, in light of the aggravators and mitigators, appellant had not demonstrated that confidence in the outcome of the penalty-phase proceeding had been undermined and therefore, appellant had not demonstrated prejudice. The court also held that while the prosecutor at length described the choices that appellant had made in his life, arguably improper comments, they were relatively brief and were not emphasized by the prosecutor. Accordingly, the court concluded that appellant had not demonstrated prejudice on this claim and therefore, his claim of ineffective assistance of counsel must fail. View "Hildwin v. State" on Justia Law

Appellant appealed an order of the circuit court denying his motion to vacate his convictions of first-degree murder and sentences of death filed under Florida Rule of Criminal Procedure 3.850 and petitioned the court for a writ of habeas corpus. At issue was whether appellant's trial counsel rendered ineffective assistance of counsel during the penalty phase because he failed to investigate, develop, and present available mitigating evidence that would have legally precluded an override of the jury's life recommendation. The court held that it was clear that trial counsel's failure to investigate, develop and present available mitigation evidence not only undermined confidence in the outcome of the trial proceedings, but also precluded the court from making a proper disposition of the case on direct appeal. The court also held that a new sentencing proceeding before a trial court was unnecessary in postconviction jury override cases, just as it was unnecessary to direct appeal jury override cases. Accordingly, the court affirmed the postconviction court's denial of rule 3.850 relief with respect to the first-degree murder convictions but reversed the court's denial of relief with respect to the death sentences. The court vacated appellant's death sentence and remanded for imposition of a life sentence on each of the first-degree murder counts and the trial court had discretion to impose the sentences concurrently or consecutively. View "Coleman v. State; Coleman v. Buss, et al. " on Justia Law