Justia Florida Supreme Court Opinion Summaries

Petitioner filed a petition to invoke the First District Court of Appeal’s all writs jurisdiction, asserting that he was serving an illegally enhanced sentence. The First District dismissed the petition in an unelaborated per curiam decision. Petitioner sought review, alleging that the First District’s decision expressly and directly conflicted with several other district court decisions regarding illegal sentences. The Supreme Court dismissed Petitioner’s petition for review, holding that the Court “lacks discretionary review jurisdiction to review an unelaborated per curiam dismissal from a district court of appeal that is issued without opinion or explanation or that merely cites to a case not pending review in, or reversed or quashed by, the Court, or to a statute or rule of procedure.”View "Wells v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed on direct appeal. Defendant subsequently filed an amended motion to vacate his judgment and sentence, which the postconviction court denied. Defendant appealed and filed an accompanying petition for writ of habeas corpus. The Supreme Court affirmed, holding (1) the postconviction court did not err in finding Defendant competent to proceed in his postconviction proceedings; (2) the postconviction court did not err in denying Defendant’s claim of ineffective assistance of trial counsel during the penalty phase and voir dire; (3) the postconviction court did not err in summarily denying Defendant’s claim that trial counsel was ineffective for failing to file a motion for a change of venue; (4) Florida’s method of execution for lethal injection is constitutional; and (5) Defendant was not entitled to relief on his claim that his right against cruel and unusual punishment would be violated because he may be incompetent at the time of execution.View "Franklin v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder under the felony murder and premeditated theories in the deaths of Berthum Gibson and Keenethia Keenan and guilty of first-degree murder under the felony murder theory in the death of Desmond Robinson. Defendant was sentenced to death for the deaths of Gibson and Keenan. The Supreme Court affirmed the convictions and sentences, holding (1) the evidence was sufficient to support Defendant’s convictions under both the felony murder and premeditation theories; (2) the trial court did not err in giving additional weight to the felony murder aggravating circumstance; (3) Defendant’s death sentences were proportional; and (4) Defendant’s death sentences were not unconstitutional under Ring v. Arizona.View "Smith v. State" on Justia Law

At issue in this case was a territorial dispute between two utilities, Choctawhatchee Electric Cooperative, Inc. and Gulf Power Company, both of which sought the right to serve Freedom Walk, a proposed multi-purpose development. The Florida Public Service Commission resolved the dispute in favor of Gulf Power, concluding that because the multiple factors it considered were substantially equal, customer preference, which favored Gulf Power, would determine the outcome of the dispute. The Supreme Court affirmed the Commission’s order granting Gulf Power the right to serve the Freedom Walk development, holding that the Commission’s findings and conclusions were supported by competent substantial evidence and were not clearly erroneous.View "Choctawhatchee Elec. Coop., Inc. v. Graham" on Justia Law

Defendant was convicted of first-degree murder, kidnapping, and sexual battery with great force. Defendant was sentenced to death. The Supreme Court affirmed Defendant’s convictions and sentence of death. Defendant subsequently filed a motion for postconviction relief, raising several allegations of error. The postconviction court denied the motion. The Supreme Court affirmed the postconviction court’s denial of relief and denied Defendant’s petition for a writ of habeas corpus, holding (1) trial counsel did not provide ineffective assistance; (2) Defendant was not entitled to relief on his claims relating to the State’s alleged use of Defendant’s co-defendant as a state agent and letters written between the co-defendant and Defendant; and (3) appellate counsel did not provide ineffective assistance. View "Johnson v. State" on Justia Law

In this contract dispute between a home health care agency, Visiting Nurse Association of Florida, Inc. (VNA), and a hospital, Jupiter Medical Center, Inc. (JMC), an arbitration panel granted VNA damages. JMC filed a motion to vacate the arbitration award, alleging that the arbitration panel construed the contract containing an arbitration provision to be an unlawful agreement. The circuit court dismissed the motion to vacate and granted the motion to enforce the award. The Fourth District Court of Appeal reversed, holding that a court must determine whether a contract is legal prior to enforcing an arbitral award based on the contract. The Supreme Court quashed the Fourth District’s decision, holding (1) the claim that an arbitration panel construed a contract containing an arbitration provision to be an unlawful agreement is an insufficient basis to vacate an arbitrator’s decision pursuant to the Federal Arbitration Act or the Florida Arbitration Code; and (2) the arbitration panel did not exceed its powers in this case. View "Visiting Nurse Ass’n of Fla., Inc. v. Jupiter Med. Ctr., Inc." on Justia Law

Walter Saunders and his wife, Ruby Saunders, sued Dr. Willis Dickens, a neurologist, filed a failure to diagnose action against Dickens after Saunders developed quadriplegia from his condition. Saunders died during the pendency of the appeal. The jury returned a general verdict in favor of Dickens. The Fourth District affirmed, holding that counsel for Dickens did not improperly shift the burden of proof when he asserted that Saunders had not established causation in light of a subsequent treating physician’s testimony that he would not have changed the course of treatment even if Dickens had not acted negligently. The Supreme Court quashed the decision below, holding that testimony that a subsequent treating physician would not have treated the patient differently had the defendant physician acted within the applicable standard of care is inadmissible and will not insulate a defendant physician from liability for his own negligence. View "Saunders v. Dickens" on Justia Law

At issue in this case was whether Florida law recognizes a “bright-line rule” that distinguishes an assignment from a sublicense. This complex commercial litigation involved an agreement wherein a licensee transferred its entire interest in a patent license agreement except for one day. A federal district court concluded that the agreement was a prohibited assignment and not a sublicense. On appeal, the Eleventh Circuit certified the question of whether a “bright-line” rule could be applied to determine whether the licensee’s transfer of its interest constituted an assignment or a sublicense. The Supreme Court answered the certified question in the negative, holding that this legal determination depends on a multiple of factors, and the ultimate resolution of whether the transfer of the licensee’s interest constitutes an assignment or a sublicense is a mixed question of law and fact. View "MDS (Canada) Inc. v. Rad Source Techs., Inc." on Justia Law

The appellate counsel of Defendant, a prisoner under a sentence of death, requested that the Supreme Court depart from its established procedure for requiring counsel to proceed with diligent appellate advocacy during mandatory review in death penalty cases where the defendant expresses a desire to be executed. Defendant in this case wished to argue in favor of the death sentence. Under Rule 4-1.2(a) of the Rules Regulating The Florida Bar, a lawyer is required to abide by her client’s decisions concerning the objectives of representation. Appellate counsel sought an order permitting him to withdraw from representation to avoid an alleged violation of his ethical responsibility to his client. The Supreme Court denied current counsel’s motion to withdraw, holding that there was no ethical violation in requiring counsel to continue to prosecute this appeal for the benefit of the Court in meeting its statutory and constitutional duties. View "Robertson v. State" on Justia Law

Appellant, a prisoner under a sentence of death for whom a death warrant had been signed, filed a successive motion for postconviction relief raising an as-applied challenge to Florida’s lethal injection protocol based on his allegation that he suffers from the medical condition porphyria. The circuit court denied Appellant’s claim without an evidentiary hearing. Appellant appealed and produced an affidavit by a physician stating that, in the physician’s expert medical opinion, a substantial risk existed that the use of midazolam hydrochloride as the first drug of Florida’s lethal injection protocol would cause Appellant “extreme or excruciating pain.” In light of these allegations, the Supreme Court relinquished jurisdiction to the circuit court. After a hearing, the circuit court denied Appellant’s claim. The Supreme Court affirmed, holding that Appellant failed to demonstrate that Florida’s lethal injection protocol, as applied to him, violated the Eighth Amendment because he did not show that allegedly suffering from porphyria creates a “substantial risk of serious harm” upon the injection of midazolam. View "Davis v. State" on Justia Law