Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of lewd and lascivious molestation of a person younger than sixteen and aggravated stalking of a minor under the age of sixteen. Defendant was sentenced as a prison releasee reoffender (PRR) to consecutive sentences for each charge. Defendant subsequently filed a motion to correct a sentencing error, arguing that his PRR sentences were illegal because his two convictions arose from a single criminal episode. The trial court denied Defendant’s motion, concluding that even if Defendant’s convictions arose from a single criminal episode, Defendant could still receive consecutive PRR sentences. The First District Court of Appeal remanded for resentencing, holding that PRR sentences may not be ordered to run consecutively when the crimes were committed during a single criminal episode and that Defendant’s convictions arose from a single criminal episode. The Supreme Court quashed the First District’s decision, holding that a trial court may impose consecutive PRR sentences on a defendant for crimes committed during a single criminal episode. View "State v. Mosley" on Justia Law

The Florida Judicial Qualifications Commission (JQC) served a notice of investigation on Circuit Judge Sandy Kautz pursuant to Rule 6(b) of the FLorida Judicial Qualifications Commissions Rules. The judge entered into a stipulation admitting that her appearance on behalf of her sister at her sister’s first appearance after an arrest was inappropriate. The judge further admitted that she had not comported herself with the requisite dignity and patience expected of her judicial office in presiding over certain types of cases. The JQC found and recommended that Judge Kautz receive a public reprimand. The Supreme Court approved of the stipulation and the JQC’s findings and recommendation. View "Inquiry Concerning Judge Sandy K. Kautz" on Justia Law

Defendant was charged with several offenses, but the trial court entered an order declaring Defendant incompetent to proceed to trial. The trial court later held a competency hearing, during which defense counsel stipulated that Defendant was competent to proceed. The court did not enter a written order determining that Defendant was competent to proceed to trial, but the matter nevertheless proceeded to a jury trial. Defendant was found guilty of two charges. On appeal, Defendant argued that the lack of a written order adjudicating him competent required reversal of his conviction and a new trial. The Fifth District Court of Appeal affirmed, concluding that the lack of a written order could be cured without a new trial because the trial court found Defendant competent based upon the stipulation of defense counsel. The Supreme Court quashed the judgment of the Fifth District in part, holding (1) Defendant’s stipulation as to his own competency did not absolve the trial court from its duty to independently make a determination of Defendant’s competency to proceed; and (2) the remedy for such a violation depends upon the circumstances of each case. View "Dougherty v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, kidnapping, and sexual battery. Defendant was sentenced to death for the murder conviction. On appeal, Defendant challenged only the propriety of the death sentence. The Supreme Court affirmed the convictions and sentence of death, holding (1) the evidence was sufficient to support the convictions; (2) the trial court did not fail to remain neutral during the penalty-phase proceedings; (3) the trial court’s findings on aggravators and mitigators were not in error with the exception of its finding of an avoid arrest aggravator, which error was harmless beyond a reasonable doubt; (4) Defendant was not entitled to relief on his claim that his death sentence was unconstitutional based on Ring v. Arizona; and (5) the death sentence in this case was a proportionate penalty. View "Davis v. State" on Justia Law

Defendant was found guilty of felony petit theft and sentenced to five years in prison. Defendant’s offense was subject to the Criminal Punishment Code, but Defendant was entitled to a nonstate prison sanction unless the court made written findings that doing so could present a danger to the public. Defendant appealed and filed a motion to correct sentencing error, arguing that because the trial court failed to enter written findings as required by Fla. Stat. 775.082(10), the upward departure sentence must be vacated and he must be resentenced to a nonstate prison sentence. The trial court denied the motion. The court of appeal held that the sentence was erroneous because the trial court failed to file the required written findings to support a departure. The court remanded for resentencing, concluding that the trial court may again impose a departure sentence on remand. The Supreme Court quashed the decision below, holding that when any upward departure sentence is vacated, a guidelines sentence must be imposed on remand. View "Bryant v. State" on Justia Law

Appellant was convicted of murder and sentenced to death. The trial court subsequently ordered a new trial, after which Appellant was again convicted of murder and sentenced to death. Appellant later filed a postconviction motion. The postconviction court ultimately denied Appellant’s postconviction motion. Appellant appealed the denial of his postconviction motion and filed a petition for a writ of habeas corpus. The Supreme Court affirmed the postconviction court’s denial of Appellant’s claims and denied habeas corpus relief, holding (1) the postconviction court properly found that Appellant was competent to proceed with his postconviction proceedings, correctly denied Appellant’s prosecutorial misconduct claim, and properly denied Appellant’s claim of a Brady violation; and (2) Appellant was not entitled to habeas relief based on his claims of ineffective assistance of appellate counsel. View "Huggins v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant’s convictions and sentences on appeal. Defendant later filed a motion for postconviction relief, raising twenty-nine claims. The circuit court denied each of Defendant’s claims. Defendant appealed the denial of five claims and filed a petition for a writ of habeas corpus, raising two additional claims. The Supreme Court affirmed the postconviction court’s denial of Defendant’s claims and denied Defendant’s petition for a writ of habeas corpus, holding (1) the postconviction court properly denied Defendant’s claims of Brady violations, ineffective assistance of trial counsel, improper juror communication, and cumulative error; and (2) Appellant was not entitled to habeas relief based on alleged ineffective assistance of appellate counsel. View "Whitton v. State" on Justia Law

Defendant was charged with one count each of grand theft and dealing in stolen property. Defendant executed a plea of guilty or no contest as to both offenses, and the trial court adjudicated Defendant of both offenses. Defendant appealed, arguing that the trial court violated Fla. Stat. 812.025 by adjudicating her guilty of both theft and dealing in stolen property. The Second District agreed with Defendant and reversed, holding that the trial court erred in adjudicating Defendant guilty of both offenses. The district court remanded with directions that the trial court vacate the grand theft conviction, the lesser offense, and to resentence Defendant accordingly. The Supreme Court quashed the district court’s decision, holding that the proper remedy on appeal in this case was to remand the case for the trial court to exercise its discretion in vacating the adjudication of guilt of either the dealing in stolen property or theft count and to resentence Defendant on the remaining count. View "Anucinski v. State" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant’s conviction and sentence, holding (1) the trial court properly considered in mitigation Defendant’s IQ score in conjunction with evidence of his low cognitive functioning; (2) Defendant was not entitled to relief on his claim that the trial court failed to consider, find, and weigh as a mitigating circumstance that Defendant had a history of drug and alcohol abuse; (3) trial court did not err in finding as aggravating circumstances that the homicide was committed in a cold, calculated, and premeditated manner and was especially heinous, atrocious, or cruel; (4) Defendant’s claim that Florida’s death penalty scheme is unconstitutional under Ring v. Arizona was without merit; (5) there was sufficient evidence to affirm Defendant’s conviction for first-degree murder; and (6) Defendant’s death sentence was proportional to other cases where the Court has upheld a sentence of death. View "Martin v. State" on Justia Law

Petitioner was convicted of four counts of armed sexual battery and ultimately sentenced to four life sentences as upward departure sentences. The second district affirmed Petitioner’s four life sentences. Petitioner later filed a motion to correct illegal sentence under Fla. R. Crim. P. 3.800(a), claiming that under Apprendi v. New Jersey and Blakely v. Washington he was entitled to a jury trial at his resentencing to determine the factual basis for the upward departure. The circuit court denied the motion, finding that Petitioner’s sentences were within their statutory maximums. The Second District affirmed, concluding that Petitioner’s claim of Apprendi error was not a ground for relief under rule 3.800(a) because it was not preserved and raised on direct appeal. The Supreme Court quashed the Second District’s decision and remanded to the district court for the application of a harmless error analysis, holding that Petitioner’s four life sentences were unconstitutionally enhanced under Apprendi and Blakely, and therefore, the sentences were illegal under rule 3.800(a). View "Plott v. State" on Justia Law