Justia Florida Supreme Court Opinion Summaries

Appellant was convicted of two counts of first-degree murder. The trial court imposed two death sentences after finding several aggravating factors. The Supreme Court affirmed on direct appeal. After Appellant's initial motion for postconviction relief was denied, Appellant filed a motion for DNA testing, which was also denied. Appellant subsequently filed in federal court a petition for a writ of habeas corpus, which was denied. Appellant then filed a successive postconviction motion, claiming that the American Society of Addiction Medicine (ASAM) Public Policy Statement defining addiction as a brain disorder was newly discovered evidence which, if presented to a jury, would probably result in a life sentence. The circuit court summarily denied the claim. The Supreme Court affirmed, holding that the ASAM definition was not newly discovered evidence, and even if the ASAM policy statement was considered to be newly discovered evidence and it was admitted at trial, it was not probable Appellant would receive a life sentence.View "Henry v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and kidnapping and sentenced to death. Appellant appealed, arguing, among other things, that (1) the trial court erred in allowing the State to ask a law enforcement officer about statements Appellant made to him during an interview without admitting the entire interview under the rule of completeness; and (2) the trial court erred in finding the avoiding arrest and cold, calculated, and premeditated (CCP) aggravators. The Supreme Court affirmed, holding (1) Appellant failed to properly preserve his first claim, and even if he had, any error in not admitting the statements under the rule of completeness was harmless beyond a reasonable doubt; (2) the trial court erred in finding the avoiding arrest aggravator, but this error was harmless, and there was competent, substantial evidence to support the finding of CCP; (3) there was sufficient evidence to support Appellant's convictions; and (4) the death sentence was proportional in this case.View "Calhoun v. State" on Justia Law

The Developer of a subdivision of a larger condominium complex (Complex) and the Complex sued the condominium association (Association), alleging that the Association failed to pay the Developer and Complex related expenses for common areas after collecting fees and assessments collected from owners of the condominium units. The Developer subsequently filed an emergency motion for the appointment of a receiver over the Association in order to facilitate the collection of the fees and assessments and to perform a proper accounting. The trial court concluded that it lacked the statutory authority to appoint a receiver in this instance. The court of appeal reversed, holding that the trial court erred as a matter of law because its right to appoint a receiver in this case was inherent in a court of equity, not a statutorily created right. The Supreme Court approved of the appellate court's decision, holding that a court's inherent equitable power to appoint a receiver over a non-profit condominium association like the Association was not limited to certain statutorily enumerated circumstances.View "Granada Lakes Villas Condo. Ass'n v. MetroDade Invs. Co." on Justia Law

Appellant was convicted of first-degree murder, burglary of a battery therein, and sexual battery with great force. Appellant was sentenced to death. The Supreme Court upheld the convictions and death sentence on appeal and later upheld the denial of postconviction relief and denied habeas relief. After Appellant was scheduled for execution, he filed a successive postconviction motion, claiming that Florida's death penalty statute violated the Eighth Amendment because most states require a unanimous jury verdict to recommend a death sentence and because alleged newly discovered evidence revealed that the number of defendants sentenced to death in Florida increased in 2012 compared to the rest of the nation. The circuit court denied relief. The Supreme Court affirmed, holding (1) non-unanimous jury recommendations to impose the sentence of death are not unconstitutional; and (2) the circuit court accurately found that the studies cited by Appellant in support of his second claim did not qualify as newly discovered evidence. View "Kimbrough v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The trial court concluded that the aggravating circumstances outweighed the mitigating circumstances and imposed upon Appellant the sentence of death. The Supreme Court affirmed Defendant’s conviction and sentence of death, holding (1) the trial court’s findings in support of the application of the cold, calculated, and premediated aggaravator were supported by competent, substantial evidence; (2) based on the totality of the circumstances and prior precedent, a sentence of death was proportionate in this case; (3) the evidence was sufficient to support Defendant’s conviction; and (4) Defendant was not entitled to relief on her claim that Florida’s death penalty statute violates Ring v. Arizona. View "Brown v. State" on Justia Law

Petitioner was convicted of aggravated assault with a firearm and sentenced as a prison releasee reoffender (PRR). Petitioner was also convicted of carrying a concealed firearm and possessing a firearm by a convicted felon and sentenced as a habitual felony offender (HFO). Petitioner was sentenced to a total of thirty-five years’ incarceration. The court of appeal affirmed Petitioner’s sentences. Petitioner subsequently filed a pro se motion for postconviction relief alleging that his thirty-five year sentence was illegal under Hale v. State, which held that sentences enhanced under the habitual violent felony offender provision of Fla. Stat. 775.084 cannot run consecutively to other sentences arising from the same criminal episode. The trial court denied Appellant’s motion for postconviction relief. The court of appeal affirmed, concluding that because the PRR statute imposes a mandatory minimum that is in accordance with, and not beyond, the statutory maximum, a PRR sentence is not an enhanced sentence, and a trial court may therefore impose an HFO sentence consecutive to a PRR sentence. The Supreme Court approved the court of appeal’s decision, holding that Hale does not prohibit a habitual offender sentence from being imposed consecutively to a PRR sentence. View "Cotto v. State" on Justia Law

The Florida Judicial Qualifications Commission (JQC) filed charges against Judge Brenda Sheehan of the Circuit Court after Sheehan pleaded guilty to the charge of driving under the influence, alleging that Judge Sheehan’s conduct violated the Code of Judicial Conduct and recommending that Judge Sheehan receive the sanction of a public reprimand. The Supreme Court approved the JQC’s findings and recommendation of a public reprimand, holding that Judge Sheehan’s conduct at issue in this case was reprehensible, undermined the public’s confidence in the integrity of the judiciary, and would not be tolerated. View "In re Sheehan" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder, attempted first-degree murder, grand theft of a motor vehicle, home invasion robbery, and aggravated assault on a police officer. The trial court imposed a sentence of death for the murder conviction. The Supreme Court affirmed the convictions and sentences. Appellant subsequently filed a motion to vacate his conviction and sentence of death pursuant to Fla. R. Crim. P. 3.851, presenting ten claims. The postconviction court summarily denied all claims except Appellant’s claim of ineffective assistance of counsel. After an evidentiary hearing, the postconviction court denied Appellant’s ineffective assistance of counsel claim. The Supreme Court affirmed the trial court’s order denying postconviction relief, holding (1) Appellant’s trial counsel were not ineffective; and (2) Appellant’s challenges to the death penalty in Florida were either waived, procedurally barred, meritless, or premature. View "Turner v. State" on Justia Law

The State charged Defendant in a two-count information with unlawful commission of a sexual battery on a “mentally defective” person over the age of twelve. The jury returned guilty verdicts on both counts. The trial court set aside the guilty verdicts and dismissed the charges, concluding that the State had not presented sufficient credible evidence to satisfy its burden of proving that the victim was “mentally defective” beyond a reasonable doubt. The court of appeal reversed and reinstated the guilty verdicts, holding that the evidence was sufficient to support a jury finding that the victim was mentally defective. The Supreme Court approved the court of appeal’s decision, concluding that the court of appeal properly construed the sexual battery statute to determine that the term “mentally defective” connotes significantly diminished judgment and could not reasonably be read to mean a total lack of mental capacity. View "Dudley v. State" on Justia Law

Plaintiff was injured when his chair collapsed at the offices of Defendant. Plaintiff sued Defendant for negligence on the grounds that Defendant had negligently failed to warn Plaintiff of the chair's dangerous condition. The trial court found in favor of Plaintiff and issued a final judgment against Defendant. The court of appeal reversed and ordered that a directed verdict be entered in favor of Defendant because Plaintiff had not established causation. The Supreme Court quashed the decision of the court of appeal, holding that the court impermissibly reweighed the testimony of expert witnesses during trial when reaching its judgment. Remanded for reinstatement of the trial court's final judgment.View "Friedrich v. Fetterman & Assocs., P.A." on Justia Law