Justia Florida Supreme Court Opinion Summaries

In 2010, voters approved an amendment to the Florida Constitution providing for express new state constitutional standards to govern the apportionment of legislative districts. Those standards were enumerated in Fla. Const. art. III, 21. Pursuant to its Fla. Const. art. III, 16 jurisdiction, the Supreme Court declared the Legislature's original plan apportioning districts for the Senate to be facially invalid, whereupon the Legislature adopted a revised plan. The Supreme Court upheld the facial validity of the revised plan. Plaintiffs subsequently filed a complaint alleging that the revised Senate map violated the express standards contained in article III, section 21. The Legislature moved to dismiss the complaint with prejudice, asserting that the circuit court lacked jurisdiction to adjudicate a challenge to the 2012 legislative apportionment plan. After the circuit court denied the motion, the Legislature sought extraordinary relief directing the circuit court to dismiss the complaint. The Supreme Court held that the circuit court had subject matter jurisdiction to adjudicate fact-based challenges to the validity of the 2012 legislative apportionment plan, that the circuit court's exercise of jurisdiction here would not interfere with the binding judgment of the Supreme Court, and that the Legislature failed to meet its burden of demonstrating entitlement to relief. View "Fla. House of Representatives v. League of Women Voters of Fla. " on Justia Law

In this case, the circuit court entered a final summary judgment of foreclosure against Borrowers regarding their shared residence. One month before the scheduled judicial foreclosure sale, Chase Home Finance, Borrowers' mortgagee, offered Borrowers an opportunity for the reinstatement of their mortgage and dismissal of the foreclosure action conditioned on Borrowers making a lump-sum payment no later than May 6. Borrowers sent a cashier's check for the full reinstatement amount to Chase's counsel, who received the cashier's check on May 4. However, Chase's counsel failed to arrange for the cancellation of the foreclosure sale, and the sale took place as scheduled. Borrowers filed a motion to vacate the sale. The third-party purchaser (Purchaser) intervened. The trial court granted Borrowers' motion and ordered all funds paid by Purchaser to be returned. The final judgment of foreclosure was also vacated and the foreclosure case dismissed. Purchaser appealed, and the court of appeal affirmed. The Supreme Court affirmed, holding (1) Borrowers alleged and proved adequate equitable grounds for the trial court to set aside the judicial foreclosure sale and dismiss the foreclosure action; and (2) proof of an inadequate bid price is not a necessary requirement to set aside a judicial foreclosure sale. View "Arsali v. Chase Home Fin., LLC" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and kidnapping. The trial court imposed a sentence of death. Defendant appealed. The Supreme Court affirmed the convictions and sentences, holding (1) the trial court did not err in limiting the defense's cross-examination of a State witness; (2) there was sufficient evidence to support Defendant's convictions; (3) the prosecutor asked improper questions of Defendant's mental health expert, but the error was harmless; (4) the trial court did not err in finding certain aggravating circumstances; (5) the trial court did not err in rejecting certain statutory mental mitigators and in assigning weight to the nonstatutory mitigation; and (6) the death sentence in this case was proportional. View "Allen v. State" on Justia Law

Several insureds filed a class action against the predecessor of Washington National Insurance Corporation concerning insurance policies that provide for reimbursement of certain home health care expenses. The district court granted summary judgment for the insureds, concluding that various provisions in the policy, including a certificate schedule, demonstrated an ambiguity concerning whether an automatic increase applied only to the daily benefit or also applied to the lifetime maximum benefit amount and the per occurrence maximum benefit amount. Because there was ambiguity in the policy, the court of appeal certified questions of law to the Florida Supreme Court, which held (1) because the policy was ambiguous, it must be construed against the insurer and in favor of coverage without consideration of extrinsic evidence; and (2) when so construed, the policy's automatic benefit increase applies to the daily benefit, the lifetime maximum benefit, and the per occurrence maximum benefit. View "Washington Nat'l Ins. Corp. v. Ruderman" on Justia Law

Plaintiff filed a claim with Defendant, his homeowner's insurance company, for fire damage on his home. Plaintiff's insurance policy with Defendant was a replacement cost policy. Defendant made a payment to Plaintiff that included costs of repair even though Defendant had not completed any repairs to the home. Defendant, however, refused to pay for a general contractor's overhead and profit because Plaintiff had not yet incurred those expenses. Plaintiff filed a breach of contract claim against Defendant, contending that, like the other costs of repair Defendant paid, Defendant was required to pay costs for overhead and profit. The trial court granted summary judgment for Defendant, and the court of appeal affirmed. The Supreme Court quashed the court of appeal's decision, holding (1) replacement cost insurance includes overhead and profit where the insured is reasonably likely to need a general contractor for repairs; and (2) the court of appeal erred in determining the Florida law and the insurance policy permitted Defendant to withhold payment of overhead and profit because Plaintiff had not actually incurred those costs. Remanded. View "Trinidad v. Fla. Peninsula Ins. Co." on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed on direct appeal. Defendant subsequently filed a motion for postconviction relief, which the postconviction court denied. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court (1) affirmed the postconviction court's denial of relief as to Defendant's guilt phase claims; (2) reversed the court's denial of relief as to Defendant's claim of ineffective assistance of trial counsel at the penalty phase, as Defendant established that he was prejudiced by his counsel's deficient performance during the penalty phase; and (3) denied Defendant's petition for writ of habeas corpus. Accordingly, the Court vacated the sentence of death and remanded for a new penalty phase proceeding. View "Shellito v. State" on Justia Law

Defendant pled guilty to first-degree murder and armed robbery and waived a penalty-phase jury. After penalty-phase proceedings in front of the trial judge, the trial court sentenced Defendant to death. The Supreme Court affirmed Defendant's convictions and sentence of death, holding (1) Defendant's guilty plea was knowingly, intelligently, and voluntarily entered; (2) any possible error in the trial court not considering polygraph results as mitigating evidence was harmless beyond a reasonable doubt; (3) the trial court did not err in not giving significant weight to the mitigator of Defendant's age, which was nineteen years old at the time of the crime; and (4) the death sentence in this case was proportional. View "Sanchez-Torres v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant's conviction and sentence of death, holding (1) the trial court did not err in instructing the jury on and in finding that the murder was especially heinous, atrocious, or cruel; (2) Defendant's death sentence was proportionate and constitutional; (3) the prosecutor did not commit misconduct in his statements during closing arguments; (4) the trial court did not err in precluding the defense from arguing a lack of violent criminal history during its penalty-phase closing argument; (5) the evidence was sufficient to support Defendant's conviction for first-degree murder. View "King v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree premeditated murder and sentenced to death for each murder. The Supreme Court affirmed the convictions and sentences on direct appeal. The postconviction court later denied Defendant's unverified postconviction motion. Defendant appealed and filed a petition seeking habeas corpus relief. The Supreme Court affirmed the trial court's order and denied the petition for a writ of habeas corpus, holding (1) Defendant waived right to prosecute his postconviction motion by refusing to sign a verification of his motion; (2) the trial court did not err in finding Defendant competent to proceed with his postconviction proceedings with the assistance of counsel; and (3) Defendant's petition for habeas corpus relief was not warranted on his claim that his case should be remanded for a determination of whether he should have been permitted to represent himself at trial. View "Hernandez-Alberto v. State" on Justia Law

After Insured sustained injuries in a car accident he sought MRIs from Virtual Imaging Services. Virtual Imaging obtained an assignment of personal injury protection (PIP) benefits under Insured's policy with GEICO and billed GEICO $3600 for the MRIs. GEICO paid the bill but limited its reimbursement to eighty percent of 200 percent of the applicable Medicare fee schedule in accordance with the formula described in Fla. Stat. 627.736(5)(a). This statutory provision became effective on January 1, 2008 as part of Florida's PIP statute. Virtual Imaging subsequently sued GEICO, alleging that GEICO's reimbursement was insufficient. The county court granted Virtual Imaging's motion for summary judgment. The court of appeal affirmed then certified a question of law to the Supreme Court, which answered by holding that GEICO was required to give notice to Insured by electing the permissive Medicare fee schedules in its policy before taking advantage of the Medicare fee schedule to limit reimbursements. View "Geico Gen. Ins. Co. v. Virtual Imaging Servs., Inc." on Justia Law