Justia Florida Supreme Court Opinion Summaries
Articles Posted in Florida Supreme Court
Barnes v. State
After waiving counsel, Defendant pled guilty to and was convicted of first-degree murder. Following the penalty phase, Defendant was sentenced to death and to terms of imprisonment for the related charges of burglary, sexual battery, and arson. The Supreme Court affirmed on direct appeal. Defendant subsequently filed a motion for postconviction relief. The circuit court summarily denied the motion. The Supreme Court affirmed, holding (1) the trial court and Defendant's standby counsel did not err in failing to order a competency evaluation before allowing him to plead guilty, as the record supported the conclusion that Defendant was competent; and (2) Defendant's claim that his death sentence violated the Eighth Amendment because he may be incompetent at the time of execution was not ripe for review. View "Barnes v. State" on Justia Law
Myles v. Crews
Defendant was convicted in 1982 to capital sexual battery and sentenced to life imprisonment. The court of appeal affirmed Defendant's conviction and sentence. Since then, Defendant made many pro se filings in the Supreme Court that were devoid of merit or inappropriate for review in the Court. At issue in this case was a recent pro se habeas petition filed by Defendant seeking to challenge his conviction and sentence. The Supreme Court dismissed the petition as unauthorized under Baker v. State. The Court also retained jurisdiction and ordered Defendant to show cause why he should not be barred from further pro se filings related to that criminal case and why the Court should not determine his filing was frivolous. After Defendant responded, the Court concluded that Defendant failed to show cause why he should not be sanctioned. Accordingly, the Court found the current finding frivolous and ordered the clerk of court to reject any future pro se pleadings or filings submitted by Defendant. View "Myles v. Crews" on Justia Law
Mungin v. State
After a trial, Defendant was convicted of first-degree murder and sentenced to death. After the denial of his first request for postconviction relief, Defendant filed a successive motion for postconviction relief, asserting that newly discovered evidence from a new witness impeached the only witness who identified Defendant as leaving the crime scene immediately after the murder, and demonstrated that the State violated Brady v. Maryland and Giglio v. United States. The postconviction court summarily denied relief. The Supreme Court remanded the Brady and Giglio claims for an evidentiary hearing but affirmed the order denying the newly discovered evidence claim. The postconviction court held an evidentiary hearing on remand and again denied relief. The Supreme Court affirmed, holding (1) substantial evidence supported the postconviction court's finding that Defendant failed to show the State willfully suppressed favorable evidence in violation of Brady; and (2) the postconviction court correctly denied Defendant's claim that the State knowingly presented false testimony in violation of Giglio. View "Mungin v. State" on Justia Law
Franks v. Bowers
After undergoing surgery, Decedent died due to complications resulting from a vein being lacerated during surgery. Decedent's wife, Plaintiff, filed a complaint against the doctor who performed the surgery and the doctor's surgical practice for medical malpractice resulting in wrongful death. Defendants moved to compel arbitration based on a financial agreement signed by Decedent prior to his surgery. The trial court entered an order compelling arbitration, and the court of appeal affirmed. Plaintiff appealed,. The Supreme Court quashed the decision compelling arbitration, holding (1) the damages clause of the arbitration provision of the financial agreement violated the public policy pronounced by the legislature in the Medical Malpractice Act; and (2) the offensive clause was not severable from the remainder of the arbitration provision. View "Franks v. Bowers" on Justia Law
Cortez v. Palace Resorts, Inc.
Petitioner, a California resident, was sexually assaulted while vacationing in Mexico. The assault occurred while Petitioner received a complimentary massage in exchange for her attendance at a resort's timeshare presentation. Petitioner sued the resort, a corporation with its primary place of business in Florida, (the Florida Defendants) for negligent vacation packaging. The Florida Defendants filed a motion to dismiss based on forum non conveniens, arguing that Mexico would be a more convenient forum. The trial court granted the motion. The court of appeal affirmed. The Supreme Court quashed the court of appeal's decision, holding that the court misapplied the forum non conveniens analysis, particularly by failing to afford a strong presumption in favor of Plaintiff's initial choice of an otherwise proper forum. View "Cortez v. Palace Resorts, Inc." on Justia Law
Ruble v. Rinker Material Corp.
Plaintiff, individually and in her capacity as the personal representative of the estate of Lance Ruble, sought to amend the original complaint filed in this action before Respondents served an answer to that complaint. The trial court dismissed Plaintiff's amended complaint, and the court of appeal affirmed. The Supreme Court reversed based on its holding in Capone v. Phillip Morris USA, Inc. (Capone II) and Boca Burger, Inc. v. Forum, holding (1) when an injured Plaintiff in a personal injury action dies, the personal representative of the decedent's estate is not required to file a separate wrongful death action but may be added as a party to the pending action and thus may file an amended pleading that alleges new claims and causes of action; and (2) the right of a plaintiff under Fla. R. Civ. P. 1.190(a) to amend a complaint once before the service of a responsive pleading is absolute, and a trial court has no discretion to deny that amendment. Remanded. View "Ruble v. Rinker Material Corp." on Justia Law
Jean-Philippe v. State
After a jury trial, Defendant was convicted of first-degree murder and aggravated battery. The trial court sentenced Defendant to death for the murder. The Supreme Court affirmed Defendant's convictions and sentences, holding (1) the trial court did not abuse its discretion in admitting evidence of text messages sent from Appellant's cell phone to the victims; (2) the trial court did not err in finding that the murder was cold, calculated, and premeditated; (3) the trial court did not abuse its discretion in giving great weight to the finding that the murder was especially heinous, atrocious, or cruel; (4) the death sentence was proportionate in this case; (5) Florida's capital sentencing scheme does not violate Ring v. Arizona; and (6) competent, substantial evidence supported the jury's finding of first-degree murder beyond a reasonable doubt. View "Jean-Philippe v. State" on Justia Law
Deviney v. State
After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. Defendant appealed, contending, among other things, that the trial court erred when it denied his motion to suppress his confession because, during his interrogation and before he confessed to the murder, he invoked his right to remain silent. The Supreme Court reversed the conviction and remanded for a new trial, holding (1) based on the totality of the circumstances, the police did not scrupulously honor Defendant's invocation of his right to remain silent; (2) there was not competent, substantial evidence supporting the trial court's finding that Defendant's confession was voluntary; and (3) this error was not harmless beyond a reasonable doubt. View "Deviney v. State" on Justia Law
Capone v. Philip Morris USA, Inc.
Frank and Karen Capone filed an action against Philip Morris USA, a tobacco manufacturer, alleging several claims. After Frank died, Karen, in her capacity as personal representative of Frank's estate, sought to amend the complaint to add a wrongful death claim. Karen also filed a motion to substitute herself as a party plaintiff. The circuit court denied Karen's motions and dismissed the entire action, concluding that the personal injury action in this case could not be amended to include a wrongful death action. Although the circuit court, upon reconsideration, granted Karen's previously-filed motions, it vacated that order, finding Karen's motion for reconsideration was not timely served. The court of appeal affirmed, holding that the original personal injury action filed by the Capones could not be amended after Frank's death to include a wrongful death claim. The Supreme Court quashed the decision of the Third District, holding that upon the death of a party plaintiff in a personal injury action, the personal representative of the decedent's estate may be added to the pending action as a party and thus may file an amended pleading that alleges new or amended claims and causes of action. Remanded. View "Capone v. Philip Morris USA, Inc." on Justia Law
Alcorn v. State
The State charged Defendant with two drug-related offenses. Defendant rejected a twelve-year plea offer after being incorrectly advised that his maximum sentence was thirty years when, in fact, Defendant faced a maximum sentence of life in prison. After trial, Defendant was found guilty of simple sale of cocaine and possession of cocaine and was sentenced to thirty years imprisonment. The court of appeal affirmed, concluding that Defendant could not show prejudice because he ultimately received the same sentence as what he was incorrectly advised. Subsequent to the court of appeal's decision, the U.S. Supreme Court issued two decisions - Missouri v. Frye and Lafler v. Cooper - concerning ineffective assistance of counsel claims in which the defendant rejected a pea offer based on misadvice. In light of these two cases, the Florida Supreme Court receded from its decisions in Cottle v. State and Morgan v. State with respect to what a defendant must show in order to demonstrate prejudice. After clarifying what a defendant must show to demonstrate prejudice, the Court quashed the court of appeal's decision because it incorrectly analyzed the prejudice prong. Remanded. View "Alcorn v. State" on Justia Law