Justia Florida Supreme Court Opinion Summaries

After a jury trial, Petitioner was convicted of first-degree murder under both premeditated and felony-murder theories. The trial court sentenced Petitioner to death. The Supreme Court affirmed Petitioner's conviction and sentence. Petitioner subsequently filed several motions for postconviction relief. This appeal concerned the denial of Petitioner's third successive motion for postconviction relief and a motion to vacate his death sentence or, in the alternative, a motion for an evidentiary hearing. Petitioner also filed a fifth state petition for writ of habeas corpus. The Supreme Court affirmed the circuit court's order dismissing Petitioner's motions, holding (1) Petitioner's claim of newly discovered evidence was without merit; (2) Petitioner's claim regarding his counsel on direct appeal was procedurally barred and without merit; and (3) Petitioner's claim of ineffective assistance of trial counsel during the penalty phase was procedurally barred. View "Van Poyck v. State" on Justia Law

After a jury trial, Defendant was convicted of burglary of a dwelling with an assault or battery, robbery with a firearm, and related offenses. Defendant appealed, challenging the admission of a witness's written statement as past recollection. Specifically, Defendant contended that a basic requirement for admission was not met because the witness did not testify to the accuracy or truthfulness of the statement. The court of appeal affirmed Defendant's convictions and sentences, holding that, under the circumstances, there was sufficient evidence to lay a foundation for admission of the witness's statement under Fla. Stat. 90.803(5) even though the witness did not confirm the accuracy of the statement at trial. The Supreme Court quashed the decision of the court of appeal, holding (1) pursuant to section 90.803(5), one of the requirements for admission of past recollection recorded hearsay is that the witness who made the statement vouch for the accuracy of the record or memorandum when the evidence is offered; and (2) in this case, a proper foundation for admission of the witness's statement of past recollection recorded was not established. Remanded. View "Polite v. State" on Justia Law

After a jury trial in 2009, Defendant was convicted of second-degree murder and sentenced to life in prison. Defendant appealed, arguing that the trial court erred by instructing the jury on manslaughter by act and that the error was fundamental. The Second District Court of Appeal affirmed Defendant's conviction and sentence, concluding that the 2008 manslaughter by act instruction did not include an intent-to-kill element, which the Supreme Court found fundamentally erroneous in State v. Montgomery. However, the Second District certified that its decision conflicted with the with the decision of the First District in Riesel v. State. The Supreme Court quashed the decision of the Second District and approved the decision of the First District in Riesel, holding (1) the 2008 standard instruction for manslaughter by act erroneously required the jury to find Defendant intended to cause the death of the victim; and (2) the trial court fundamentally erred in giving the 2008 standard jury instruction in this case. Remanded for a new trial. View "Daniels v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and robbery with a deadly weapon. The trial court imposed a sentence of death. Defendant subsequently filed a postconviction motion, which was denied. Defendant appealed the denial of his motion and also filed a petition for writ of habeas corpus asserting ineffective assistance of appellate counsel. The Supreme Court affirmed, holding (1) the trial court did not err in finding Defendant's trial counsel was not ineffective for (i) deciding not to present the testimony of a mental health expert in the penalty phase to establish mental mitigation, (ii) failing to move for a change of venue, and (iii) failing to object to certain prosecutorial comments during the guilt phase closing argument; (2) Florida's capital sentencing scheme is constitutional; and (3) Defendant was not prejudiced by appellate counsel's failure to argue on direct appeal that the trial court improperly failed to assign weight to each mitigator and evaluate the relative weights of the aggravating and mitigating factors in its sentencing order. View "Taylor v. State" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death. With a minor exception, the Supreme Court denied Defendant's requests for postconviction relief and his petitions for writs of habeas corpus. In this postconviction action, Defendant filed a motion requesting postconviction DNA testing on six items collected by law enforcement in connection with the investigation of the victim's murder. Of these items, the State was only able to locate one of them. The circuit court summarily denied Defendant's motion. The Supreme Court affirmed, holding that there was no reasonable probability that Defendant would have been acquitted or received a lesser sentence if DNA evidence from any of the requested items had they been admitted at his trial. View "Jackson v. State" on Justia Law

Compass Construction and First Baptist Church were named as defendants in an action arising from a construction accident. Ultimately, First Baptist prevailed against the plaintiff in the main action and on its cross-claim for indemnity against Compass. First Baptist was awarded attorneys fees as part of its indemnity claim, but the parties disagreed about the appropriate hourly rate at which the fee for First Baptist's attorney should be calculated. In the main action, First Baptist's insurance company assigned an attorney to represent First Baptist. The attorney had a written fee agreement with the insurance company providing that attorney would be paid $170 per hour. In an alternative fee recovery clause, however, the agreement provided that if anyone other than the insurance company was required to pay attorney's fees, the attorney's hourly rate would be $300. The trial court calculated the award at the higher rate. The court of appeal reversed. The Supreme Court reversed, holding that the alternative fee recovery clause was valid. Remanded for reinstatement of the judgment awarding attorney's fees. View "First Baptist Church of Cape Coral, Fla., Inc. v. Compass Constr., Inc." on Justia Law

Defendant pled guilty to several crimes, including grand theft and first-degree felony murder. The trial court imposed the death sentence. The Supreme Court affirmed Defendant's convictions but vacated his sentence and remanded for a new penalty phase. On remand, the trial court again sentenced Defendant to death. The Supreme Court affirmed. Defendant subsequently filed an amended motion for postconviction relief, which the trial court denied after a hearing. Defendant appealed and filed a petition for writ of habeas corpus. The Supreme Court affirmed, holding, inter alia, (1) Defendant failed to show his counsel was constitutionally deficient; (2) the postconviction court did not abuse its discretion in denying Defendant's motion to disqualify the postconviction court's judge; and (3) appellate counsel provided effective assistance. View "Farr v. State" on Justia Law

Two decisions of the Third District Court of Appeal were before the Supreme Court here. In the first case (Public Defender), the Public Defender for the Eleventh Judicial Circuit filed motions in several criminal cases seeking to be relieved of the obligations to represent indigent defendants in non-capital felony cases. The trial court permitted the Public Defender to decline appointments in future third-degree felony cases. The court of appeal reversed. In the second case (Bowens), an assistant public defender filed a motion to withdraw from representing a defendant, alleging that his excessive caseload created a conflict of interest. The circuit court granted the motion, but the court of appeal reversed. The Supreme Court (1) quashed the court of appeal's decision in Public Defender and remanded, holding (i) aggregate/systemic motions to withdraw are appropriate where there is an office-wide or widespread problem as to effective representation, and (ii) the Public Defender demonstrated cause for withdrawal in this case; and (2) quashed in part and affirmed in part the decision in Bowens, holding that Fla. Stat. 27.5303(1)(d) is facially constitutional but should not preclude a public defender from filing a motion to withdraw based on excessive caseload or underfunding that would result in ineffective representation of indigent clients. View "Public Defender, Eleventh Judicial Circuit of Fla. v. State" on Justia Law

Child was born with birth-related neurological injuries. Child's parents (Petitioners) filed a claim for compensation under the Florida Birth-Related Neurological Injury Compensation Plan. The Florida Birth-Related Neurological Injury Compensation Association agreed to pay parental compensation of $100,000 to both parents jointly under Fla. Stat. 766.31(1)(b)(1), which provides for an award not exceeding $100,000 to the parents or legal guardians of an infant found to have sustained a birth-related neurological injury. Petitioners reserved the right to have a hearing before an ALJ to raise the issue of the interpretation and constitutionality of section 766.31(1)(b)(1). The ALJ denied Petitioners' claim for an additional $100,000 as part of the parental award, finding that the Legislature clearly intended that the maximum award of $100,000 was for both parents, not for each parent. The district court upheld the ALJ's judgment and denied each of Petitioners' constitutional claims. The Supreme Court approved the district court's decision, holding that the parental award provision (1) unambiguously provides for only a single award of $100,000; (2) does not violate equal protection; and (3) neither is void for vagueness nor unconstitutionally limits the right of access to courts. View "Samples v. Fla. Birth Related Neurological Injury Comp. Ass'n" on Justia Law

Petitioner Raymond James Financial Services required its clients (the investors) to sign an agreement to arbitrate all disputes arising out of the handling of their investments. At issue in this case was whether Florida's statute of limitations that is applicable to a "civil action or proceeding" applies to arbitration proceedings. In 2005, the investors filed a joint claim for arbitration against Raymond James, alleging federal and state securities violations and negligent supervision. The investors filed an action in state court seeking a declaration that the statute of limitations applied only to judicial actions and thus did not limit the time in which to bring their arbitration claims. The trial court granted declaratory judgment in favor of the investors. The court of appeal affirmed. The Supreme Court concluded that the investors' arbitration claims in this case were barred by the statute of limitations, holding that Florida's statute of limitations applies to arbitration because an arbitration proceeding is within the statutory term "civil action or proceeding" found in Fla. Stat. 95.011. View "Raymond James Fin. Servs., Inc. v. Phillips" on Justia Law