Justia Florida Supreme Court Opinion Summaries

S.A. filed a notice of expiration of speedy trial and a motion seeking a discharge under the speedy trial rule, alleging that he was entitled to a discharge because the State failed to bring him to trial within the fifteen-day recapture window. The State argued that it had brought S.A. to trial within the recapture window because (1) the recapture window consists of two separate five- and ten-day periods calculated pursuant to the computation of time rule; and (2) the hearing on S.A.’s motion was held within five days of the date S.A. filed his motion, and S.A. was brought to trial within ten days of the hearing. The trial court discharged S.A. The court of appeal affirmed, holding that the recapture window is one fifteen-day time period. The Supreme Court quashed the decision of the court of appeals, holding (1) the recapture window is calculated as two separate five- and ten-day time periods; and (2) therefore, S.A. was not entitled to a discharge. View "State v. S.A." on Justia Law

ICI Homes, Inc. (ICI) had a general liability insurance policy with General Fidelity Insurance Company. In 2007, Katherine Ferrin, the owner of a residence constructed by ICI, was injured while using stairs installed by Custom Cutting, Inc. Ferrin filed suit against ICI. ICI, in turn, sought indemnification from Custom Cutting. The parties agreed to a $1.6 million settlement of Ferrin’s claim. ICI accepted $1 million from Custom Cutting’s insurer to settle its indemnification claim, which it paid to Ferrin. ICI and General Fidelity then claimed the other was responsible for paying Ferrin the remaining $600,000. Both parties paid $300,000 to Ferrin to settle Ferrin’s claim. ICI then filed suit against General Fidelity seeking return of the $300,000 ICI paid above the $1 million indemnification payment. General Fidelity counterclaimed seeking return of the $300,000 it had paid to Ferrin. The district court entered judgment for General Fidelity. The court of appeals certified two questions to the Supreme Court for resolution. The Supreme Court answered (1) the General Fidelity policy allowed ICI to apply indemnification payments received from Custom Cutting’s insurer towards satisfaction of its $1 million self-insured retention; and (2) the transfer of rights provision in the policy did not abrogate the made whole doctrine.View "Intervest Constr. of Jax, Inc. v Gen. Fidelity Ins. Co." on Justia Law

After a jury trial, Appellant was convicted of the first-degree murder, kidnapping, and sexual battery of a nine-year-old and sentenced to death. After the Governor signed the warrant in this case Appellant filed numerous public records requests, a second successive motion for postconviction relief, and a request for a stay of execution. The circuit court denied Appellant's public records requests, his postconviction petition, and his request for a stay of execution. The Supreme Court affirmed in all respects, holding that the circuit court did not err in its rulings. View "Chavez v. State" on Justia Law

Plaintiff filed a medical malpractice wrongful death action against Cedars Healthcare Group, a facility at which Plaintiff’s father was a patient when he died, and other health care providers. Plaintiff sought records of adverse medical incidents from Cedars pursuant to Fla. Const. art. X, 25, which guarantees patients the right to “have access to any records made or received in the course of business by a health care facility or provider relating to any adverse medical incident.” The trial court overruled Cedars’ objection to the discovery request. Cedars subsequently petitioned the district court for a writ of certiorari. Citing to Fla. Stat. 381.028(7)(a), the district court granted the petition on the ground that the request to produce asked for “records of adverse medical incidents involving patients other than the plaintiff” but did not limit the production of those records to the same or substantially similar condition as the patient requesting access. Prior to the district court’s decision, the Supreme Court, in Florida Hospital Waterman, Inc. v. Buster, declared section 381.028(7)(a) invalid. Accordingly, the Court quashed the decision of the district court in this case and remanded for reconsideration pursuant to Buster. View "Ampuero-Martinez v. Cedars Healthcare Group" on Justia Law

After a second jury trial, Appellant was convicted of first-degree murder and robbery and was sentenced to death. The Supreme Court affirmed the convictions but twice remanded for new penalty phases. Each time, the trial court sentenced Defendant to death. The Supreme Court affirmed the sentence of death. Appellant subsequently moved to vacate judgment of convictions and sentences, alleging ineffective assistance of counsel. The postconviction court denied all claims presented in Appellant’s motion to vacate. The Supreme Court affirmed, holding that the postconviction court did not err in denying Appellant’s claims of ineffective assistance of counsel during his second guilt phase trial and during his fourth penalty phase trial.View "Lebron v. State" on Justia Law

The Florida Attorney General petitioned the Supreme Court for an advisory opinion as to the validity of a proposed citizen initiative amendment to the Florida Constitution and the accompanying Financial Impact Statement. Upon review, the Supreme Court approved the proposed amendment and Financial Impact Statement for placement on the ballot, concluding (1) the proposed amendment satisfies the single-subject requirement of Fla. Const. art. XI, 3 because it embraces a single subject, which is the medical use of marijuana; (2) the ballot title and summary comply with the clarity requirements of Fla. Stat. 101.161(1) because they give voters fair notice as to the chief purpose and scope of the proposed amendment and will not affirmatively mislead voters regarding the purpose of the proposed amendment; and (3) the Financial Impact Statement complies with Fla. Stat. 100.371(5).View "Advisory Opinion to the Attorney General Re Use of Marijuana for Certain Medical Conditions" on Justia Law

Buyers purchased two condominium units pursuant to contracts entered into in 2006. Buyers later contended that the contracts were voidable because Seller failed to maintain Buyers’ deposits in escrow in the manner required by the Condominium Act (the Act). The trial court dismissed the claims against Seller. The Third District Court of Appeal reversed, concluding (1) the contracts were voidable under the escrow provisions of the Act that were in force in 2006; and (2) the application of a 2010 amendment to the Act that was intended to have retroactive effect and that removed a statutory ground for determining that the contracts were voidable violated the constitutional prohibition on the impairment of vested contractual rights. The Supreme Court reversed, holding (1) the 2010 amendment did not make a substantive change in the law; and (2) the contracts were not voidable under the statutory provisions in force in 2006.View "N. Carillon, LLC v. CRC 603, LLC" on Justia Law

Petitioner was convicted and sentenced to thirty years imprisonment for robbery. The court of appeal affirmed the judgment of guilty and the sentence imposed. Thereafter, Petitioner filed numerous postconviction claims. The petition filed in this case was Petitioner’s twenty-seventh petition for review or extraordinary writ petition filed in the Supreme Court pertaining to his criminal case. The petition was one for a writ of habeas corpus. The Court dismissed the petition as unauthorized pursuant to Baker v. State and issued an order directing Petitioner to show cause why he should not be prohibited from filing any further pro se filings in the Court related to his criminal case. Petitioner did not file a response but instead filed several handwritten “motions” asserting the same challenges to his conviction and sentence that he presented in other filings. The Supreme Court denied the motions, concluded that Petitioner’s petition was procedurally barred as well as a frivolous proceeding, and imposed sanctions upon Petitioner. View "Lockhart v. Crews" on Justia Law

After Respondent violated his conditional release, the parole examiner recommended that Respondent be restored to regular supervision. The Florida Parole Commission (FPC) rejected the parole examiner’s recommendation and revoked Respondent’s conditional release. Respondents subsequently filed a pro se petition for a writ of habeas corpus, which the circuit court denied. Respondent then filed a pro se petition for a writ of certiorari, arguing that the FPC failed to follow Florida’s Administrative Procedures Act by rejecting the parole examiner’s recommendation. The district court granted the petition. The FPC petitioned the Supreme Court for review on the basis that the district court’s decision expressly and directly conflicted with Sheley v. Florida Parole Commission. The Supreme Court quashed the district court’s decision, holding (1) the district court’s decision exceeded the scope of second-tier certiorari review; and (2) the district court erred in granting certiorari relief because the circuit court’s decision did not result in a miscarriage of justice.View "Fla. Parole Comm’n v. Taylor" on Justia Law

Petitioner was convicted of second-degree murder. In a previous habeas corpus proceeding, Petitioner sought release from incarceration, arguing that the assistant state attorney who signed the information and indictment in his criminal case was not authorized to sign informations and indictments because he did not have an oath on file. The court of appeal denied the petition as time-barred and meritless. Petitioner subsequently filed a petition for writ of mandamus in the Supreme Court asking the Court to compel the court of appeal to carry out its “legal ministerial duty” to grant him habeas corpus relief. The Supreme Court dismissed the petition as an unauthorized use of the writ of mandamus, as mandamus is not the proper vehicle to seek review of an allegedly erroneous decision by a lower court.View "Mathews v. Crews" on Justia Law