Justia Florida Supreme Court Opinion Summaries

Adrien Mobley was murdered in 1987, and for fifteen years, the case languished. DNA testing finally led investigators to Defendant. After a jury trial in 2011, Defendant was convicted of the murder and aggravated battery of Mobley and was sentenced to death for the murder conviction. The Supreme Court reversed and vacated both of Defendant’s convictions and sentences, holding that there was a lack of competent substantial evidence to conclude, beyond a reasonable doubt, that Defendant was the person responsible for Mobley’s death, as the competent substantial evidence linked Defendant to Mobley’s car, not Mobley’s murder. Remanded for a judgment of acquittal. View "Dausch v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed the conviction and sentence on appeal. Appellant subsequently filed a postconviction motion seeking to vacate his conviction and sentence as well as a motion seeking a ruling that he was ineligible to be executed due to mental retardation. The postconviction court denied both motions. Appellant appealed the denial of his motions and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the postconviction court's orders and denied Appellant's habeas petition, holding (1) Appellant was not entitled to relief on any of his claims raised in his motion for postconviction relief; (2) Appellant was not entitled to relief on his mental retardation-related claims; and (3) Appellant's habeas claims were not properly presented in a petition for a writ of habeas corpus, and thus, Appellant was not entitled to habeas corpus relief. View "Diaz v. State" on Justia Law

After a jury trial in 1985, Appellant was convicted of first-degree murder and sexual battery. Appellant later filed a motion for postconviction relief seeking to have his convictions vacated after newly discovered evidence revealed that there was no seminal fluid found in the victim. At the time of Appellant's trial, the Florida law enforcement department tested vaginal and anal swabs of the victim and got a positive result for acid phosphatase (AP). The AP evidence was crucial to the State's case that a sexual battery occurred especially since the victim was found fully clothed and the medical examiner relied on the now-discredited testing that AP was present in order to conclude the victim was sexually battered. The newly discovered evidence also impacted the first-degree murder conviction because without evidence that a sexual battery occurred, the evidence linking Appellant to the murder was scant. The circuit court denied relief. The Supreme Court reversed and vacated Appellant's convictions and sentences, holding that the newly discovered evidence weakened the case against Appellant so as to give rise to a reasonable doubt as to his culpability. Remanded for a new trial.View "Swafford v. State" on Justia Law

Two women, DMT and TMH, agreed to jointly conceive and raise a child together. The child was conceived through the use of assisted reproductive technology. TMH provided the egg, and DMT gave birth to the child. The couple participated in raising their child together until their relationship ended and DMT absconded with the child. TMH sought to establish her parental rights to the child and to reassume parental responsibilities. The court of appeal concluded that Florida's assisted reproductive technology statute was unconstitutional as applied to TMH because it automatically deprived TMH of her ability to assert her fundamental right to be a parent. The Supreme Court affirmed, concluding that, based on the circumstances of this case, the statute was unconstitutional as applied to abridge TMH's fundamental right to be a parent and violated state and federal equal protection by denying same-sex couples the statutory protection against the automatic relinquishment of parental rights that it affords to heterosexual unmarried couples seeking to utilize the assistance of reproductive technology. Remanded. View "D.M.T. v. T.M.H." on Justia Law

After certain Florida criminal defendants were charged with driving under the influence (DUI), they sought the computer source codes of the breathalyzer equipment manufactured by CMI, Inc., a Kentucky-based corporation, by serving CMI's registered agent in Florida. The source code material was not located in Florida. The court of appeal held that criminal defendants must follow the procedures set forth in the Uniform Law to Secure the Attendance of Witnesses from Within or Without a State in Criminal Proceedings (Uniform Law) when requesting this source code material from out-of-state, nonparty witnesses and that service on CMI's registered agent was insufficient to compel CMI to produce the source codes. The Supreme Court approved of the court's decision, holding (1) in criminal cases, in order to subpoena documents located in another state that are in the possession of an out-of-state nonparty, the party requesting the documents must utilize the procedures of the Uniform Law; and (2) the issuance of the subpoenas at issue in this case lacked the statutory authority to require the out-of-state records custodian to comply because the criminal defendants did not first follow the procedures required by the Uniform Law.View "Ulloa v. CMI, Inc." on Justia Law

Petitioner was convicted of several crimes. The Fifth District Court of Appeal affirmed the convictions and sentences on direct appeal. Petitioner subsequently filed a motion for postconviction relief. The trial court partially granted relief on Petitioner’s sentencing claim, thus ordering resentencing, and partially denied relief as to Petitioner’s remaining postconviction claims. Fifteen days later, Petitioner filed a motion for rehearing challenging the denial of his other postconviction claims. The trial court denied relief. The Fifth District dismissed Petitioner’s appeal for lack of jurisdiction, determining that the trial court’s order partially denying and partially granting postconviction relief was not final until Petitioner’s resentencing was completed. The Supreme Court quashed the Fifth District’s decision, holding that an order disposing of a postconviction motion which partially denies and partially grants relief is a final order for purposes of appeal, even if the relief granted requires resentencing. View "Taylor v. State" on Justia Law

Plaintiff-corporation filed a lawsuit against Defendant-insurer for personal injury protection benefits. The parties settled the case, and the trial court entered an order of dismissal with prejudice. After the attorney for Plaintiff learned of the dismissal order, he moved to vacate the order of dismissal based on excusable neglect so that he could file his motion for attorney’s fees. The county court vacated the initial dismissal, but the circuit court reversed and reinstated the order of dismissal. Plaintiff filed a petition for common law certiorari. The Fourth District Court of Appeal granted the petition and quashed the decision of the circuit court. Plaintiff subsequently filed a motion for attorney’s fees. The Fourth District denied the motion on the basis of the Supreme Court’s holding in Stockman v. Downs, concluding that because Plaintiff did not request fees in the petition or reply, the motion was untimely. The Supreme Court quashed the decision below to the extent it held that, pursuant to Stockman, a request for attorney’s fees in Fla. R. App. P. 9.100 original proceedings must be made in the petition, a response, or a reply. Remanded. View "Advanced Chiropractic & Rehab. Ctr. v. United Auto. Ins. Co." on Justia Law

Petitioners filed a petition for extraordinary writ relief concerning certain documents in the possession of Respondents, non-parties to litigation regarding the constitutional validity of the 2012 plan apportioning Florida’s congressional districts under the Fair Districts Amendments. Petitioners contended that the documents demonstrated “the surreptitious participation of partisan operatives in the apportionment process," but the First District Court of Appeal precluded the admission of the documents. The Supreme Court granted relief to Petitioners and stayed the enforcement of the First District’s order, holding that the circuit court was not precluded from admitting the documents into evidence, subject to a proper showing of relevancy, but that the court must maintain the confidentiality of the documents by permitting disclosure or use only under seal in a courtroom closed to the public. View "League of Women Voters v. Data Targeting, Inc." on Justia Law

After a jury trial at which Appellant represented himself, Appellant was convicted of the first-degree murders of his parents and sentenced to death. The Supreme Court affirmed the convictions and death sentences, holding (1) the trial court did not err by allowing Appellant to continue to represent himself during a hearing regarding Appellant’s competence to proceed; (2) Appellant’s challenge to the constitutionality of Florida’s capital sentence statute under Ring v. Arizona was without merit; (3) competent, substantial evidence supported the convictions; and (4) the death sentences imposed in this case were proportionate. View "Larkin v. State" on Justia Law

The South Florida Water Management District alleged that RLI, Live Oak, LLC, a land developer and owner of property that purportedly contained wetlands, participated in unauthorized dredging, construction activity, and filling of wetlands without first obtaining the District’s approval. The circuit court entered judgment in favor of the District and awarded the District $81,900 in civil penalties. The district court reversed, holding that the trial court erred in basing its findings on a preponderance of the evidence standard and not the clear and convincing evidence standard. On motion for rehearing or certification, the district court certified a question for a determination by the Supreme Court of the proper burden of proof. The Supreme Court reversed, holding that where the Legislature statutorily authorizes a state governmental agency to recover a “civil penalty” in a “court of competent jurisdiction” but does not specify the agency’s burden of proof, the agency is not required to prove the alleged violation by clear and convincing evidence but, rather, by a preponderance of the evidence. View "S. Fla. Water Mgmt. Dist. v. RLI Live Oak, LLC" on Justia Law