Justia Florida Supreme Court Opinion Summaries

Petitioner Andrea Johnson plead guilty to armed robbery and possession of a firearm, and was placed on probation for four years conditioned on his participation in a "boot camp" program. Johnson violated the terms of the probation. The State and Johnson reached an agreement on sentencing which specified that Johnson would receive a sentence of four years of incarceration, and credit for time served. The court clerk executed a document reflecting the agreement, but Johnson asserted the agreement should have received credit for the time spent in boot camp, which was outside the time covered by the agreement. The trial court denied Johnson's pro se motion seeking credit for time spent in boot camp. On appeal, the court upheld the lower court's decision, holding that Johnson validly waived any additional credit in consenting to the terms of the plea agreement. Petitioner Bernard Joyner's case was procedurally similar to Johnson's: Joyner plead guilty to false imprisonment, and was sentenced to five years probation. Violating the terms of his probation, Joyner and the State reached a plea agreement where Joyner would be sentenced to two years on incarceration. The court clerk executed an agreement for time served. Joyner asserted that he should have received additional credit for time served, but the trial court denied his motion. The appellate court denied both petitioners relief; the Supreme Court consolidated the cases and affirmed the appellate court's decision, finding that Petitioners' challenged are not cognizable under state law.

Respondent Enterprise Leasing Company leased a motor vehicle to Elizabeth Price for less than a year. Her son crashed the leased vehicle into a vehicle owned by Petitioner Rafael Vargas. Vargas filed suit against Price and Enterprise. The only count of the complaint directed at Enterprise claimed that the company was vicariously liable as the owner of the vehicle, pursuant to state law section 324.021(9)(b)2. Vargas did not contend that Enterprise was negligent, that its lease to Price was improper, or that it was in any way at fault for the accident. Enterprise filed an Answer and affirmative defenses, asserting that pursuant to 49 U.S.C. §30106, or the "Graves Amendment," it had no liability. The circuit court granted Enterprise's motion for summary judgment, ruling that the Graves Amendment preempted state law, holding that the state law was a vicarious liability provision and not a financial responsibility one. The court entered a final judgment consistent with Enterprise's consent to judgment, and Vargas appealed. The appellate court affirmed the lower court's decision and held one issue for review by the Supreme Court: whether the Graves Amendment as enacted by Congress preempted state law involving short term leases of motor vehicles. Florida had eliminated vicarious liability for a certain category of owner/lessors; Congress, through the Graves Amendment, sought to eliminate vicarious liability for that category of owners/lessors in which the state law left exposed to liability. On analysis, the Supreme Court found that the savings clause of the Graves Amendment does not supersede state laws that impose financial responsibility on the owner of a vehicle or that impose liability on businesses who rent or lease vehicles for failure to meet financial responsibility requirements under state law, and affirmed the decision of the circuit court.

Appellant-Cross Appellee Seibert was denied a post-conviction motion to vacate his first-degree murder conviction and death sentence. On appeal, Appellant sought review of whether the post-conviction court erred in denying his claim of ineffective assistance of counsel during the guilt and sentencing phases of trial, and whether that court erred in denying him access to public records. In raising this appeal, Appellant sought a writ of habeas corpus. The State cross-appealed the post-conviction court's order to produce certain records on lethal injection protocols. After review of lower court records and trial transcripts, the Court found that Appellant was not entitled to relief and affirmed the post-conviction court''s disposition of the case, an denied Appellant the writ of habeas corpus. The Court upheld the lower court's ruling on the State's public records cross-appeal.

The Court considered whether a "sniff test" by a drug detection dog conducted at the front door of a private residence is a "search" under the Fourth Amendment, and if so, whether the evidentiary showing of wrongdoing that the government must make prior to conducting such a search is probable cause or reasonable suspicion. A Crimestoppers tip alerted police to a private home where drugs were suspected; officers arrived at the house with a drug detection dog. The dog alerted to the scent of marijuana, and on approaching the house, police then smelled the scent. The magistrate supressed the evidence seized at the home, and the State appealed. Petitioner Jardines sought review by the Court on a certified question that conflicted with state law pertaining to whether the "sniff test" was a violation of his constitutional rights. Concluding that the dog "sniff test" conducted here was an intrusive procedure because it took place in the home, the Court held that results of the "sniff test" were properly withheld from the magistrate's probable cause determination.