Justia Florida Supreme Court Opinion Summaries

Petitioner, a juvenile, was arrested and charged with aggravated battery on a victim whom Petitioner knew or should have known was pregnant. Petitioner was on probation at the time of her arrest. Prior to the adjudicatory hearing, it was determined that Petitioner's risk assessment score on her risk assessment instrument (RAI) should be zero. The trial court then placed Petitioner in home detention. Petitioner filed a petition for a writ of habeas corpus, arguing that because her risk assessment score was zero, the trial court could not place her in home detention. Petitioner did not submit a copy of her RAI with her petition. The court of appeal found (1) Petitioner was not required to submit the RAI to properly consider the petition, and (2) because Petitioner's RAI score was zero, the trial court erred in placing her in home detention. The Supreme Court quashed the court of appeal's decision, holding (1) a district court may not grant a juvenile's pre-adjudicatory habeas petition when the court is not presented with the juvenile's RAI; and (2) a juvenile may be placed in home detention with a risk assessment score of zero when the juvenile qualifies for home detention under the specific terms of the RAI. View "State v. S.M." on Justia Law

Respondent pleaded guilty to drug-related offenses. After Respondent violated the conditions of his probation, the trial court revoked his probation and sentenced him to ninety-six days in jail with ninety-six days credit for time served. In so sentencing Respondent, the trial court imposed a downward sentence under Fla. Stat. 921.0026(2)(d), which authorizes a downward sentence if the “defendant requires specialized treatment for a mental disorder that is unrelated to substance abuse or addiction or for a physical disability, and the defendant is amenable to treatment.” The State appealed, arguing that because Respondent did not present evidence that the Department of Corrections (DOC) could not provide the specialized treatment, insufficient evidence supported the trial court’s decision to impose a downward departure sentence. The district court disagreed with the State. The Supreme Court affirmed, holding that the plain language of the statute does not require the defendant to prove that the specialized treatment is unavailable in the DOC. View "State v. Chubbuck" on Justia Law

After a retrial, Appellant was convicted of the first-degree murder of his second wife. After an unsuccessful appeal and the denials of Appellant’s petitions for postconviction and habeas relief, the Governor signed a death warrant for Appellant and scheduled an execution date. Postconviction counsel subsequently requested a competency hearing under Fla. Stat. 922.07. Three experts reported after an examination that Appellant did not suffer from a psychiatric illness or intellectual disability and understood that nature of the death penalty and why the sentence had been imposed on him. Thereafter, Appellant filed a motion for determination of intellectual disability as a bar to execution, which the circuit court dismissed as untimely. The Supreme Court affirmed the postconviction court’s order dismissing Appellant’s motion, holding that Appellant did not demonstrate a facially sufficient claim of intellectual disability. View "Henry v. State" on Justia Law

Appellant was convicted of first-degree murder and sentenced to death. Appellant’s conviction and death sentence were affirmed on direct appeal. Appellant subsequently filed a motion for postconviction relief, asserting eleven claims. The circuit court denied relief on all of Appellant’s claims. Appellant appealed and filed a petition for a writ of habeas corpus. The Supreme Court affirmed the denial of Appellant’s motion for postconviction relief and denied his habeas petition, holding (1) Appellant’s trial counsel did not provide ineffective assistance during the guilt phase or penalty phases of trial; (2) Appellant’s due process rights were not violated by the State’s institutional policy of reprocessing tape recordings of tips received by Crimeline, a crime reporting hotline, including a recording of a tip that implicated him in the crime of which he was charged; and (3) Appellant’s challenges to Florida’s capital sentencing scheme were without merit. View "McLean v. State" on Justia Law

Defendant was convicted of robbing and killing Johnny Parrish and burning down Parrish's house. The trial court sentenced Defendant to death for the first-degree murder conviction. Defendant subsequently filed two postconviction motions and two additional petitions for a writ of habeas corpus, all of which were denied. Defendant then instituted this second successive postconviction motion, raising three claims. After an evidentiary hearing, the postconviction court denied relief. The Supreme Court affirmed, holding (1) Defendant failed to meet his burden to demonstrate that the State knowingly presented false or misleading evidence that it failed to correct at Defendant's trial in violation of Giglio v. United States; and (2) Defendant failed to show that newly discovered evidence was of "such a nature that it would probably produce an acquittal on retrial."View "Moore v. State" on Justia Law

In 2002, Petitioner was convicted of first-degree murder and sentenced to life imprisonment. Following his unsuccessful appeal, Petitioner filed numerous postconviction claims and extraordinary writs, all without success. This case involved Petitioner’s tenth petition for an extraordinary writ pertaining to his criminal case. The Supreme Court 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 and why the Court should not determine that the petition filed here was frivolous and subject to disciplinary procedures. The Court ultimately concluded that sanctions should be imposed and that Petitioner’s petition was a frivolous proceeding. View "Bush v. Crews" on Justia Law

In 2010, the legislature amended state law to preempt regulation of red light cameras to the state. At issue in these consolidated cases was whether pre-2010 municipal ordinances imposing penalties for red light violations detected by camera devices were invalid because they were preempted by state law. The district courts in these cases reached contrary conclusions: the Third District Court of Appeal held that the City of Aventura’s ordinance was a valid exercise of municipal power, and the Fifth District Court of Appeal concluded that the City of Orland’s ordinance was invalid because it was in conflict with and was preempted by state law. The Supreme Court agreed with the Fifth District, holding that the ordinances at issue were invalid because they were expressly preempted by state law. View "Masone v. City of Aventura" on Justia Law

Lakeview Reserve Homeowners Association filed an action against Maronda Homes, Inc. for breach of the implied warranties of fitness and merchantability (referred to as the implied warranty of habitability in the residential construction context) arising from alleged defects in the development and construction of a residential subdivision that Maronda Homes developed. Maronda Homes filed a third-party complaint against T.D. Thomson Construction Company for indemnification based on the alleged violation of the implied warranties. The trial court entered summary judgment in favor of Maronda Homes and T.D. Thompson on the basis that the common law implied warranties of fitness and merchantability do not extend to the construction and design of the infrastructure, private roadways, drainage systems or other common areas in a residential subdivision because those structures do not immediately support the residences. The court of appeal reversed, holding that the common law warranty of habitability was applicable in this case. The Supreme Court affirmed, holding that the implied warranties of fitness and merchantability applied to the improvements that provided essential services to the homeowners association. Remanded.View "T.D. Thomson Constr. Co. v. Lakeview Reserve Homeowners Ass'n, Inc." on Justia Law

Defendant was convicted of the 1985 first-degree murder of his wife. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s conviction and sentence. After Defendant’s postconviction motion and petition for writ of habeas corpus were denied, the Governor signed a death warrant for Defendant setting execution for June 18, 2014. Defendant filed a motion for determination of intellectual disability as a bar to execution, which the circuit court dismissed. The Supreme Court affirmed, holding that Defendant did not demonstrate a facially sufficient claim of intellectual disability and that no motion for rehearing would be entertained by the Court. View "Henry v. State" on Justia Law

Petitioners, inmates under a sentence of death, challenged the facial validity of four provisions of the Timely Justice Act of 2013, which was enacted to “reduce delays in capital cases and to ensure that all appeals and postconviction actions in capital cases are resolved as soon as possible after the date a sentence of death is imposed in the circuit court.” The disputed portions of the Act were the provisions that governed conflict of interest and substitute counsel, constitutionally deficient representation, capital postconviction public records production, and the issuance of a warrant of execution. The Supreme Court denied the petition, holding that the challenged provisions of the Act did not facially violate the constitution. View "Abdool v. Bondi" on Justia Law