Justia Florida Supreme Court Opinion Summaries

In 1972, Petitioner was convicted and sentenced to life imprisonment for committing capital sexual battery. In a separate case, Petitioner pled guilty to of unlawful use of a motor vehicle. From 1992 forward, Petitioner filed multiple pro se extraordinary writ petitions and other proceedings with the Supreme Court seeking relief from his conviction and sentence. None of the petitions for relief was granted. In the instant case, Petitioner filed pro se petitions for writs of habeas corpus. The Court dismissed the petitions as unauthorized pursuant to Baker v. State and found them to be frivolous proceedings. Because the petitions were dismissed as unauthorized and also were the ninth and tenth pro se proceedings initiated by Petitioner in the Court, and because Petitioner failed to show cause why he should not be sanctioned, the Court instructed the clerk of court to reject any future pleadings, petitions or filings submitted by Petitioner related to his criminal cases. View "McCutcheon v. State" on Justia Law

Defendant was convicted of first-degree murder and robbery with a deadly weapon. Defendant appealed, arguing that the trial judge erred in refusing to allow Defendant to call a witness despite defense counsel's determination that calling the witness would not be of benefit to Defendant's case. The Fourth District court of appeal held that determining which witnesses should be called by the defense is not a fundamental decision to be made by the defendant himself, and therefore, the trial court did not err in its judgment. The Fourth District subsequently certified conflict with the Fifth District's decision in Cain v. State. The Supreme Court (1) approved the decision of the Fourth District in this case and disapproved the decision of the Fifth District in Cain, holding that defense counsel has the final authority as to whether or not the defense will call a particular witness to testify at the criminal trial; and (2) receded from its decision in Blanco v. State to the extent it held that the ultimate decision rests with the defendant as to the presentation of witnesses. View "Puglisi v. State" on Justia Law

Petitioner was convicted under Fla. Stat. 790.19 for shooting into an unoccupied vehicle. The trial court determined Petitioner qualified as a prison releasee reoffender (PRR) under the forcible felony catch-all provision of the PRR statute and thus sentenced him to a prison term of fifteen years for the conviction. Petitioner filed a motion for postconviction relief disputing the validity of his sentence, claiming that his conviction was not a qualifying felony under the forcible felony catch-all provision of the PRR statute. The trial court denied the motion, and the fourth district court of appeal affirmed. The court, however, certified conflict with the first district's decision in Crapps v. State. The Supreme Court (1) approved the fourth district's decision, finding that the offense of shooting into an occupied vehicle necessarily involves the use or threat of physical force or violence against an individual, and therefore, qualifies as a forcible felony under the catch-all provision of the PRR statute; and (2) disapproved the opinion in the conflicting case of Crapps. View "Paul v. State" on Justia Law

Plaintiffs filed a class action complaint against a check advance company, asserting claims based on numerous Florida statutes. Plaintiffs later amended the complaint to add Tiffany Kelly as an additional plaintiff and named class member. Because Kelly had signed the version of Defendant's arbitration agreement that contained a class action waiver, this case focused on her contracts with Defendant. The trial court eventually denied Defendant's motion to compel arbitration, ruling that the class action waiver was unenforceable because it was void as against public policy. The court of appeal affirmed, finding that no other reasonable avenue for relief would be available if it enforced the class action waiver. After the court of appeal decided this case, the U.S. Supreme Court issued its decision in AT&T Mobility, LLC v. Concepcion. Applying the rationale of Concepcion to the facts set forth in this case, the Supreme Court quashed the court of appeal's decision, holding that the Federal Arbitration Act preempted invalidating the class action waiver in this case on the basis of the waiver being void as against public policy. View "McKenzie Check Advance of Fla., LLC v. Betts" on Justia Law

After Defendant, an inmate, committed several sexual offenses in Florida and Georgia, the state attorney initiated civil commitment proceedings against him under the Jimmy Ryce Act. Almost four years later, Defendant, who was still in custody, filed a motion to dismiss the commitment petition, arguing that he was not in lawful custody at the time commitment proceedings were initiated because his sentence had expired due to postconviction credit for time previously served. The circuit court denied the motion to dismiss based on its determination that Defendant was in lawful custody when commitment proceedings were initiated. The district court dismissed the commitment petition and ordered the immediate release of Defendant from custody, concluding that the circuit court did not have jurisdiction to adjudicate the commitment petition because Defendant was not in lawful custody when the State initiated commitment proceedings. The Supreme Court approved the district court's decision, holding that Defendant was not in lawful custody at the time the commitment procedures were initiated because his incarcerative sentence had already expired. View "State v. Phillips" on Justia Law

Law Firm, located in Virginia, leased a vehicle from Company. Tortfeasor, who was driving the car with permission by Law Firm, collided with a car driven by Plaintiff. The day before the accident, the insurance policy on the vehicle lapsed for nonpayment. Plaintiff filed suit in Florida against Law Firm, Tortfeasor, and Company, alleging that because Company had failed to comply with the insurance requirements of Fla. Stat. 324.021(9)(b)(1), Company was vicariously liable for Tortfeasor's negligent operation of the car under Florida's dangerous instrumentality doctrine. Company moved for summary judgment, contending that its liability should be based on Virginia tort law and that if Florida law applied, section 342.021(9)(b)(1) was preempted by the Graves Amendment, a federal law providing that the owner of a motor vehicle who leases the vehicle shall not be vicariously liable from harm that results from the operation of the vehicle during the lease. The trial court concluded that Florida law applied but that the Graves Amendment did preempt section 324.021(9)(b)(1). The court of appeal affirmed. The Supreme Court approved the decision, holding that the Graves Amendment preempts section 324.021(9)(b)(1). View "Rosado v. Daimlerchrysler Fin. Servs. Trust" on Justia Law

Defendant was convicted and sentenced to death for the kidnapping and murder of a ten-year-old. The Supreme Court affirmed Defendant's conviction on direct appeal but remanded for resentencing. After resentencing, when Defendant was again sentenced to death, the Supreme Court affirmed Defendant's sentence. Defendant filed several postconviction motions, which were denied. Defendant filed the instant motion to vacate sentence and requested certain public records after his execution date was set. The circuit court summarily denied relief on all claims. Defendant appealed and filed a petition for a writ of habeas corpus. The Supreme Court affirmed and denied habeas corpus relief, holding (1) the majority of Defendant's claims were without merit; (2) the circuit court properly denied Defendant's records requests because the requested records were not relevant to a colorable claim; and (3) Defendant's petition for habeas corpus was untimely. View "Mann v. State" on Justia Law

EB Acquisitions I (EB) entered into a written contract to purchase real property from DK Arena. The parties orally agreed to modify their contract for the sale of the property by extending the due diligence deadline. After the original due diligence period expired, EB attempted to terminate the contract of sale and sought a return of its deposit. DK Arena filed suit alleging breach of contract. EB asserted several counterclaims, including breach of contract. The trial court held in favor of EB on all claims, concluding that the oral agreement was valid and enforceable, notwithstanding the Statute of Frauds, under the doctrine of promissory estoppel. The court ruled that EB retained an unqualified right to terminate the contract and obtain the return of its deposit. The Supreme Court quashed the decision of the district court to the extent it was inconsistent with this opinion, holding that the district court applied an improper estoppel exception to the Statute of Frauds in express and direct conflict with the Court's decision in Tanenbaum v. Biscayne Osteopathic Hospital, Inc. Remanded. View "DK Arena, Inc. v. EB Acquisitions I, LLC" on Justia Law

Defendant was convicted of attempted murder, among other crimes, and was sentenced to various terms of imprisonment, including a fifty-five-year term. Defendant's convictions and sentences were affirmed on appeal. After unsuccessfully making a number of filings in the Supreme Court challenging his convictions and sentences, Defendant filed a pro se petition for writ of mandamus with the Court. Because the petition filed in this case was without merit, and because Defendant submitted multiple other meritless filings seeking relief relating to his criminal case that demonstrated an ongoing pattern of abuse of the judicial process, the Court (1) instructed the clerk of court to reject any filings submitted by Defendant relating to his criminal court case; and (2) found Defendant's current petition to be frivolous and directed the clerk of court to forward a copy of this opinion to the Department of Corrections' institution or facility where Defendant was incarcerated. View "Nelson v. Crews" on Justia Law

Defendant was convicted of robbery and murder and was sentenced to death. Based on newly discovered evidence, Defendant's counsel filed a postconviction motion. After an evidentiary hearing, counsel filed a motion for reimbursement of counsel, also requesting that the court issue an order directing the payment of his investigative fees. The chief judge of the judicial circuit denied the motion for reimbursement based on the fact that the expenses exceeded the statutory cap for investigative expenses by $1,844. The Supreme Court reversed, holding (1) the trial court improperly focused on whether this was an "ordinary" capital case, as opposed to reviewing whether there were "extraordinary or unusual circumstances" that required defense counsel to exceed the statutory cap for investigative expenses; and (2) based on the record, counsel's actions and the expenses incurred were reasonable and necessary, and the case presented "extraordinary or unusual circumstances" that required defense counsel to exceed the statutory cap for investigative services. View "McClain v. Circuit Court" on Justia Law