Justia Florida Supreme Court Opinion Summaries

Appellant was convicted of two counts of first-degree murder, two counts of kinapping, and two counts of robbery. The trial court imposed two sentences of death for each murder. The Supreme Court affirmed on appeal. Appellant later filed a motion for postconviction relief, raising twelve issues. After an evidentiary hearing conducted on two of Appellant’s claims, the postconviction court denied relief. The Supreme Court affirmed, holding that the postconviction court did not err in denying Appellant’s claims that trial counsel was ineffective during the guilt phase, during the penalty phase, and during jury selection. View "Wade v. State" on Justia Law

After a jury trial, Norman McKenzie was convicted of two counts of first-degree murder. The trial court sentenced McKenzie to death for the murders. The Supreme Court affirmed the convictions and sentences. McKenzie later filed a motion to vacate the convictions and sentences pursuant to Fla. R. Crim. P. 3.851, asserting four claims. The postconviction court summarily denied the motion without an evidentiary hearing. McKenzie appealed and also petitioned for a writ of habeas corpus. The Supreme Court affirmed, holding (1) McKenzie’s ineffective assistance of counsel claim, in which he presented several issues arising from his decision to represent himself during his capital criminal proceeding, was properly denied; (2) McKenzie was not entitled to a second proportionality review at the postconviction appellate stage for evidence he chose not to present during his capital trial; and (3) McKenzie was not entitled to relief on his claim that because he was mentally ill, to execute him would be unconstitutional. View "McKenzie v. State" on Justia Law

Santana Morales died while working for Lawns Nursery and Irrigation Designs, Inc. (Lawns). Thereafter, Lawns’ surviving spouse entered into a workers’ compensation settlement agreement with Lawns and Zenith Insurance Company (Zenith), Lawns’ workers’ compensation and employer liability insurance carrier. In a separate wrongful death lawsuit, Morales’ Estate obtained a default judgment against Lawns. Zenith refused to pay the tort judgment, and the Estate sued Zenith under Lawns’ employer liability policy. A federal district court entered summary judgment for Zenith, holding that the policy’s workers’ compensation exclusion barred the Estate’s suit. On appeal, the Eleventh Circuit certified three questions of law to the Supreme Court. The Court answered (1) the Estate had standing to bring direct action against Zenith to recover the judgment against Lawns; (2) the workers’ compensation exclusion barred coverage of the Estate’s tort judgment under the employer liability policy; and (3) a release in the workers’ compensation settlement agreement, through which Mrs. Morales elected the consideration described in the agreement as the sole remedy with respect to the insurance coverage that Zenith provided to Lawns, precluded the Estate from collecting the tort judgment from Zenith. View "Morales v. Zenith Ins. Co." on Justia Law

Appellant was convicted of first-degree murder, attempted armed robbery, and grand theft of a motor vehicle. The trial court imposed a sentence of death for the murder conviction. The Supreme Court affirmed on appeal. Appellant later filed a motion for postconviction relief, alleging twelve claims. After an evidentiary hearing, the postconviction court denied Appellant’s motion to the extent that it requested a new guilt phase but granted the motion to the extent that it requested a new penalty phase. Appellant appealed and filed a petition for a writ of habeas corpus. The Supreme Court affirmed the postconviction court’s order and denied Appellant’s habeas petition, holding (1) the postconviction court did not err in denying Appellant’s request for a new guilt phase trial; and (2) Appellant failed to establish that he was entitled to habeas corpus relief. View "Blake v. State" on Justia Law

Fla. Stat. 550.054(14)(a), effective July 1, 2010, sets forth the standards a holder of a permit to conduct jai alai must meet to convert the permit to a permit to conduct greyhound racing in lieu of jai alai. Two businesses d applied for the conversion of their jai alai permits on the day section 550.054 became effective. The Department of Business and Professional Regulation, Division of Pari-Mutuel Wagering (DBPR) granted the applications. Thereafter, Appellees instituted a declaratory judgment alleging that section 550.054(14) was an unconstitutional special law. The trial court entered judgment in favor of the two businesses and DBPR, concluding that the statute was a general law. The First District reversed, concluding that section 550.054(14)(a) was unconstitutional. The Supreme Court reversed, holding that the statute is a valid general law. View "Fla. Dep’t of Bus. & Prof’l Regulation v. Debary Real Estate Holdings, LLC" on Justia Law

In 2001, Petitioner was convicted for one count of first-degree murder and one count of home invasion robbery and sentenced to life imprisonment on the murder conviction. Since 2006, Petitioner filed at least twenty-three extraordinary writ petitions. The current case came before the Supreme Court on Petitioner’s petition for a writ of habeas corpus. The Court denied Petitioner’s petition and expressly retained jurisdiction to pursue any possible sanctions against Petitioner based upon the volume of his meritless and inappropriate filings. After considering Petitioner’s response to the Court’s show cause order, the Court determined that the response failed to show cause why sanctions should not be imposed. The Court subsequently concluded that Petitioner’s habeas petition was a frivolous proceeding and instructed the Clerk of Court to reject any future pro se filings submitted by Petitioner. View "Clark v. Crews" on Justia Law

Defendant was convicted of three counts of attempted felony murder, which were predicated upon the underlying felony of attempted second-degree murder. As to each separate count, Defendant’s sole act was the discharge of a firearm at a group of individuals who were the victims of both the attempted felony murder and the attempted second-degree murder. The Third District Court of Appeal affirmed Defendant’s three convictions for attempted felony murder. The Supreme Court quashed the Third District’s decision, holding that while the act of discharging a firearm may be able to support attempted second-degree murder, the discharge of a firearm at the same individuals cannot support attempted felony murder, which requires the defendant to commit an “intentional act that is not an essential element of the underlying felony.” Remanded for a new trial on the underlying felony of attempted second-degree murder. View "Milton v. State" on Justia Law

In 2012, individuals and groups challenging the constitutional validity of a 2012 congressional redistricting plan issued a subpoena duces tecum to Pat Bainter, the president of Data Targeting, Inc., a political consulting company. The challengers sought certain documents in the possession of Bainter, Data Targeting, and the company's employees (collectively, Appellants) related to the redistricting litigation. Bainter did not file a motion for a protective order or raise any legal objection to producing the documents sought by the challengers but instead attended a deposition testifying that he had produced what he had found, which was a limited amount. After being served with additional subpoenas duces tecum including the disputed documents within their scope, and during six months of hearings and filings regarding document production, Appellants did not raise any claim of a First Amendment privilege. It was only after Appellants were held in contempt of court that Appellants raised a belated claim of a qualified First Amendment privilege. Ultimately, the trial court ordered that Appellants produce 538 pages of the disputed documents. The Supreme Court affirmed, holding that, based on the totality of the circumstances, Appellants’ belated assertions of a qualified First Amendment privilege had been waived. View "Bainter v. League of Women Voters of Fla." on Justia Law

Beach Community Bank filed an action against the City of Freeport. The City moved to dismiss the complaint pursuant to the doctrine of sovereign immunity. The trial court entered a nonfinal order finding that the City was not immune from suit based on sovereign immunity. The First District Court of Appeal determined that the City’s claim to sovereign immunity rested on a pure question of law and that it could exercise its certiorari jurisdiction to review the trial court’s nonfinal order, ultimately concluding that the City was entitled to sovereign immunity. In deciding whether to accept review in this case, the Supreme Court noted that a proposed amendment to Fla. R. App. P. 9.130 permits district courts to review nonfinal orders of decisions determining entitlement to sovereign immunity where the case involves a pure legal question. The Court held (1) because this case fell squarely within the new rule amendment, the City should be entitled to the benefit of the new rule; and (2) the City was entitled to sovereign immunity regarding the question presented here. Remanded. View "Beach Cmty. Bank v. City of Freeport" on Justia Law

Due to a dispute between the Citrus County Hospital Board and the Citrus Memorial Health Foundation, Inc., the Legislature enacted a special law that reeancted the Board’s charter. Section 16 of the charter included subsections that specifically addressed the Board’s relationship with the Foundation. The Foundation filed suit against the Board seeking a declaratory judgment that the the special law was an unconstitutional impairment of the parties’ contracts. The circuit court granted summary judgment for the Board, concluding (1) the Foundation was prohibited from challenging the constitutionality of the special law because it was a public or quasi-public corporation; and (2) the special law did not impair the Foundation’s contracts. The First District Court of Appeal reversed, holding that, as applied to the Foundation, the special law significantly altered the parties’ contractual rights and was an unconstitutional impairment of their contracts. The Supreme Court affirmed, holding (1) the Contract Clause of the Florida Constitution applies to the Foundation’s contracts; and (2) as applied, the special law unconstitutionally impairs the Foundation’s contracts. View "Citrus County Hosp. Bd. v. Citrus Memorial Health Found., Inc." on Justia Law