Justia Florida Supreme Court Opinion Summaries

The Florida Virtual School sued K12, Inc. and K12, Florida, LLC (collectively, K12) for trademark infringement. K12 asserted that the Florida Virtual School had no standing because the authority to file an action with regard to the trademarks at issue was vested exclusively in the Florida Department of State. The district court dismissed the case for lack of standing. On appeal, the Eleventh Circuit certified a question to the Supreme Court for determination under Florida law. The Supreme Court answered that the Florida Virtual School’s statutory authority to acquire, enjoy, use, and dispose of trademarks, and the designation of its board of trustees as a body corporate with the powers of a body corporate and the authority for the proper operation and improvement of the School, necessarily included the authority to file an action to protect those trademarks. View "Fla. Virtual Sch. v. K12, Inc." on Justia Law

In 1989, Petitioner was sentenced to terms of incarceration for robbery and aggravated battery convictions. Neither of those sentences was imposed under the habitual offender statute. While incarcerated, Petitioner was convicted of inmate possession of contraband and sentenced under the habitual offender statute to a term of incarceration. The provisional release date for Petitioner reflected only the 410 days of provisional credits that he acquired prior to his sentence as a habitual offender. Petitioner challenged the Florida Department of Correction’s (DOC) award of provisional credits, claiming he was eligible for 1,080 days of provisional credits for the robbery and aggravated burglary sentences. The DOC responded that an inmate sentenced as a habitual offender was no longer eligible to receive provisional credits on non-habitual offender sentences. The First District denied Petitioner’s petition for writ of certiorari. The Supreme Court approved the First District’s decision, holding that Fla. Stat. 944.277 renders an inmate ineligible to receive provisional credits on any sentence after the inmate has received a habitual offender sentence, even where the habitual offender sentence is imposed subsequent to a sentence that is otherwise eligible for provisional credits. View "Leftwich v. Fla. Dep’t of Corr." on Justia Law

After a jury trial, Appellant was convicted of the kidnapping, capital sexual battery, and first-degree murder of an eleven-year-old girl. The trial court sentenced Appellant to death for the murder. The Supreme Court affirmed Appellant’s convictions and sentences on appeal. Appellant subsequently filed a motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, presenting several claims. The postconviction court summarily denied all claims. The Supreme Court affirmed, holding (1) Appellant’s argument that criminal defense counsel should have unlimited authority to conduct interviews to probe jurors for possible misconduct was without merit; (2) the postconviction court properly denied Appellant’s claims that the trial court improperly instructed the jury regarding its role; (3) the postconviction court did not err when it held that Florida’s capital sentencing statute is not unconstitutional; and (4) Appellant’s challenge to the constitutionality of Florida’s lethal injection procedures was without merit. View "Smith v. State" on Justia Law

Appellant was convicted and sentenced to death for the first-degree murder of Monquell Wimberly. Appellant was also convicted of the first-degree felony murder of Patrick Stafford, for which Stafford was sentenced to life imprisonment. The Supreme Court affirmed Appellant’s convictions and sentence of death, holding (1) there was no fundamental error in the admission of a videotaped statement Appellant gave to detectives after he was taken into custody; (2) there was no prejudicial error in the admission of a codefendant’s out-of-court statement; (3) the admission of testimony concerning an eyewitness’s fear of the shoot did not constitute fundamental error; (4) Appellant was not entitled to relief on his claim of juror misconduct or premature deliberation; and (5) competent, substantial evidence supported the verdict of guilt as to the first-degree murder conviction and the felony murder conviction. View "Sheppard v. State" on Justia Law

In Sirota v. State, the court of appeal certified a question to the Supreme Court regarding the scope and proper application of the Court’s decision in Morgan v. State. Thereafter, the Supreme Court decided Alcorn v. State, wherein the Court receded from Morgan with respect to the standard for establishing prejudice as to ineffective assistance of counsel claims in which the defendant rejected a plea offer based on misadvice. After Alcorn became final, the Court issued an order directing the defendant below to show cause why the Court should not summarily quash the court of appeal’s decision in Sirota and remand for reconsideration in light of Alcorn. After the parties responded, the Supreme Court quashed the court of appeal’s decision in Sirota and remanded for further proceedings consistent with the Court’s decision in Alcorn. View "State v. Sirota" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder and one count of armed carjacking. The trial court sentenced Appellant to death. The Supreme Court affirmed Appellant’s convictions and sentences on appeal. Appellant subsequently filed a motion for postconviction relief, raising twenty-eight claims. After an evidentiary hearing on several of those claims, the circuit court denied relief. Appellant appealed, raising twenty-one claims, and also filed a habeas petition raising two claims of ineffective assistance of appellate counsel. The Supreme Court (1) affirmed the postconviction court’s order denying relief on all postconviction claims, holding that Appellant failed to establish that any errors occurred which, either individually or cumulatively, would entitle him to a new trial; and (2) denied relief on both claims Appellant raised in his petition for writ of habeas corpus, as both claims were procedurally barred. View "Deparvine v. State" on Justia Law

Appellant was convicted of first-degree murder in the shooting death of a law enforcement officer, which occurred after the officer stopped Appellant for a traffic infraction. The jury recommended that the death penalty be imposed, and the circuit court sentenced Appellant to death. Appellant filed an amended motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, alleging that his trial counsel provided ineffective assistance. The court below denied the motion in a final order. The Supreme Court affirmed, holding that Appellant failed to satisfy the Washington v. Strickland standard in the postconviction proceeding held below. View "Bailey v. State" on Justia Law

Florida Power & Light (FPL) filed an application for a rate base increase. Three intervenors to the proceedings and FPL reached a negotiated settlement agreement. After evidentiary hearings pertaining exclusively to the settlement agreement, the Florida Public Service Commission (Commission) approved the settlement agreement, finding that it established fair, just, and reasonable rates and that it was in the public interest. Citizens of the State of Florida (Citizens) appealed the decision of the Commission. The Supreme Court affirmed, holding (1) the Commission did not violate the essential requirements of the law or commit a material error in procedure by approving the negotiated settlement agreement over Citizens’ objection; (2) the procedures followed by the Commission did not violate Citizens’ due process rights; and (3) the Commission’s findings and conclusions were support by competent, substantial evidence and were not clearly erroneous. View "Citizens of the State of Fla. v. Pub. Serv. Comm’n" on Justia Law

This case arose from a malfunctioning HVAC system installed in a new building owned by Caduceus Properties. Caduceus sued Michael Gordon, the building architect, and Gordon initiated a third-party action against KTD Consulting Engineers and William Graney, who designed the HVAC system. The third-party claims were dismissed. After the statute of limitations governing Caduceus’ original action had expired, Caduceus successfully amended its complaint to name third-party defendants, KTD and Graney, as party defendants to the action. The trial court ruled against KTD and Graney. The court of appeal reversed, holding that the amended complaint did not relate back and was barred by the statute of limitations. The Supreme Court remanded, holding (1) an amended complaint, filed after the statute of limitations has expired, that names a party who had previously been made a third-party defendant as a party defendant, relates back under Fla. R. Civ. P. 1.190(c) to the filing of the third-party complaint; and (2) for the amended pleading to be timely in this situation, the third-party complaint must have been filed prior to the expiration of the statute of limitations, and the plaintiff’s claims in the amended complaint must arise from the same conduct, transaction, or occurrence set forth in the third-party complaint. View "Caduceus Props., LLC v. William G. Graney, P.E." on Justia Law

Appellant was convicted of first-degree murder and sentenced to death for killing a Florida Highway Patrol Trooper. The Governor set a death warrant for Appellant and scheduled his execution for February 26, 2014. This appeal concerned the denial of Appellant’s amended third successive motion for postconviction relief in which he challenged the Florida lethal injection protocol as applied to him. The Supreme Court affirmed the postconviction court’s denial of relief, holding (1) Appellant's suggestion that the Court depart from its established precedent as to the proper standard to apply to an Eighth Amendment challenge to the lethal injection protocol was unavailing; (2) the use of midazolam hydrochloride in the 2013 lethal injection protocol does not violate the Eighth Amendment; (3) the forced administration of vecuronium bromide does not violate Appellant’s Fourteenth Amendment rights under Sell v. United States because the holding of Sell does not apply to these circumstances; and (4) the postconviction court did not err in denying Appellant’s request to strike a witness’s testimony.View "Howell v. State " on Justia Law