Justia Florida Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of one count of first-degree murder, four counts of armed kidnapping, and one count of armed robbery. Appellant was sentenced to death for the murder conviction. The Supreme Court affirmed, holding (1) the prosecutor’s method of impeachment after Appellant’s prior conviction record was entered into evidence was improper, but the error was harmless; (2) the State did not violate either the spirit or the technical requirements of the criminal discovery rules by refusing to transcribe a witness’s recorded statement for Defendant; (3) the trial court erred by prohibiting Appellant from attempting to refresh a witnesses’s recollection, but the error was harmless; (4) Appellant’s right to compulsory process was not violated; (5) the trial court erred in finding an avoid arrest aggravating circumstance, but the error was harmless; (6) Defendant’s death sentence was proportionate; and (7) there was sufficient evidence to support Appellant’s convictions. View "Wilcox v. State" on Justia Law

Appellant was convicted for the 1998 first-degree murder of Cynthia Harrison and sentenced to death. Concluding that the trial court erred in denying Appellant’s postconviction claim of ineffective assistance of counsel, the Supreme Court remanded for a new penalty phase hearing. The trial court subsequently entered an order sentencing Appellant to death. The Supreme Court affirmed the sentence, holding (1) the trial court did not err in finding that Appellant was not mentally retarded and exempt from execution; (2) constitutional error did not occur because the advisory jury in the penalty phase was not required to expressly find specific aggravators or issue a unanimous advisory verdict on the sentence; and (3) Appellant’s death sentence, when compared to the death sentences in other comparable capital cases, was proportionate. View "Hurst v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder and one count of armed carjacking. The trial court sentenced Defendant to death on both murder counts. The Supreme Court affirmed Defendant’s convictions and sentences. Defendant subsequently filed a motion for postconviction relief, raising twenty-eight claims. After an evidentiary hearing, the circuit court denied relief. Defendant appealed the denial of his postconviction motion, raising twenty-one claims, and also petitioned the Supreme Court for a writ of habeas corpus, raising two claims of ineffective assistance of appellate counsel. The Supreme Court affirmed the postconviction court’s denial of relief on all claims and denied habeas corpus relief, holding (1) Defendant failed to establish that any errors occurred that, either individually or cumulatively, would entitle him to a new guilt phase trial; and (2) Defendant’s claims of ineffective assistance of appellate counsel were procedurally barred. View "Deparvine v. State" on Justia Law

Defendant was charged with both grand theft and dealing in stolen property. Because the grand theft and dealing in stolen property charges arose from one scheme or course of conduct, the trial court dismissed the grand theft count. Defendant was then convicted of dealing in stolen property. Defendant appealed, arguing that the trial court should have instructed the jury that it could return a verdict for dealing in stolen property or grand theft, but not both. The court of appeal certified questions to the Supreme Court that the court certified in Williams v. State. The Supreme Court stayed proceedings pending disposition of Williams, in which the Court held that the defendant’s convictions for dealing in stolen property and grand theft violated Fla. Stat. 812.025 and that the trial court erred in precluding defense counsel from arguing that the jury could find the defendant guilty of either offense. After Williams was decided, the Supreme Court granted Petitioner’s petition for review, quashed the court of appeal’s decision, and remanded for further proceedings consistent with Williams. View "Culpepper v. State" on Justia Law

Defendant was charged with both grand theft and dealing in stolen property in connection with one scheme or course of conduct. Defendant argued that under Fla. Stat. 812.025, the trial court was required to instruct the jury that it could convict him of either grand theft or dealing in stolen property, but not both. The trial court rejected Defendant’s argument. A jury returned guilty verdicts of both offenses. The State subsequently filed a motion to dismiss the grand theft charge, which the trial court granted. Defendant unsuccessfully filed a motion for a new trial, asserting that the trial court erred by failing to comply with section 812.025. The court of appeal affirmed the convictions. The Supreme Court stayed proceedings pending disposition of Williams v. State, in which the Court held that the defendant’s convictions for dealing in stolen property and grand theft violated Fla. Stat. 812.025 and that the trial court erred in precluding defense counsel from arguing that the jury could find the defendant guilty of either offense. After Williams was decided, the Supreme Court granted Petitioner’s petition for review, quashed the court of appeal’s decision, and remanded for further proceedings consistent with Williams. View "Crosby v. State" on Justia Law

Plaintiff filed a lawsuit against Defendant, her former employer, alleging that Defendant took adverse employment actions against her after she revealed that she was pregnant. The trial court dismissed Plaintiff’s lawsuit for failure to state a cause of action. The court of appeal affirmed, concluding that Florida law does not prohibit pregnancy discrimination in employment practices. The Supreme Court quashed the court of appeal’s decision and remanded with directions that the trial court reinstate Plaintiff’s complaint, holding that the provision in the Florida Civil Rights Act (FCRA) making it an unlawful employment practice for an employer to discriminate based on an individual’s sex includes discrimination based on pregnancy, which is “a natural condition and primary characteristic unique to the female sex.” View "Delva v. Continental Group, Inc. " on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder. Appellant was sentenced to death for the murders. The Supreme Court affirmed the convictions and sentences. Appellant subsequently filed a motion to vacate the convictions and sentences pursuant to Fla. R. Crim. P. 3.851, asserting four claims. The postconviction court summarily denied Appellant’s motion without an evidentiary hearing. Appellant appealed the summary denial of his motion and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of the Rule 3.851 motion and denied the petition for writ of habeas corpus, holding, among other things, that (1) Appellant was afforded constitutionally effective assistance of trial counsel; (2) Appellant’s allegation of improper argument by the prosecution was procedurally barred; and (3) Appellant’s claim that to execute him would be unconstitutional because he was mentally ill was without merit. View "McKenzie v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Appellant’s convictions of first-degree murder and his sentences of death on appeal. Appellant subsequently filed a motion to vacate judgment of conviction and death sentence. After an evidentiary hearing, the circuit court denied the motion. The Supreme Court affirmed the circuit court’s denial of Appellant’s postconviction motion and denied habeas relief, holding (1) trial counsel did not render constitutionally deficient assistance by failing to object to the striking of a minority venireperson, failing to object to certain comments made by the trial court and the State, failing to file a motion to preclude the State from seeking the death penalty, and failing to investigate and present certain mitigation evidence; (2) Florida’s method of execution by lethal injection did not violate Appellant’s constitutional rights; and (3) appellate counsel was not ineffective for failing to raise on appeal the unconstitutionality of the strike of the minority venireperson. View "Frances v. State" on Justia Law

Robert Christensen ("Robert") paid for a vehicle, and the certificate of title was placed in the name of Robert and his wife, Mary, as co-owners. Thereafter, Mary struck and killed Thomas Bowen while driving the vehicle. Mary Jo Bowen ("Bowen"), the executor of her husband’s estate, filed an action for wrongful death against both Mary and Robert, alleging that Robert, as an owner of the vehicle, was vicariously liable for Mary’s negligence under the dangerous instrumentality doctrine. Robert argued that he purchased the vehicle as a gift to Mary and that, afterwards, he had no involvement with the vehicle. Bowen unsuccessfully moved for a directed verdict on the issue of ownership. The jury subsequently found that Robert was not an owner of the vehicle. The district court reversed. The Supreme Court approved the district court’s ruling, holding (1) a person whose name is on the certificate of title of a vehicle as co-owner may not avoid vicarious liability under an exception to the dangerous instrumentality doctrine by asserting that he never intended to be the owner of the vehicle and further claiming that he relinquished control to a co-owner of the vehicle; and (2) therefore, Robert was the owner of the vehicle as a matter of law. View "Christensen v. Bowen" on Justia Law

Defendant was convicted of one count each of burglary with an assault or battery, a first-degree felony, and strong-arm robbery, a second-degree felony. The sentencing judge sentenced Defendant to concurrent life sentences for each conviction. Defendant subsequently filed a motion to correct an illegal sentence, alleging that a life sentence on the second-degree felony conviction was impermissible. The trial court granted the motion without holding a hearing and resentenced Defendant on the robbery count. Defendant appealed, arguing that he was entitled to be present at his resentencing. The Third District Court of Appeal affirmed. The Supreme Court held (1) resentencing Defendant in his absence was error because, under Fla. R. Crim. P. 3.180(a), Defendant was entitled to be present; but (2) the error was harmless because Defendant was serving a concurrent, true life sentence on another count, with no practical consequences. View "Jordan v. State" on Justia Law