Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of sexual battery for penetrating the victim’s vagina with his penis and lewd or lascivious molestation for intentionally touching the victim’s breasts, genitals, genital area, buttocks, or the clothing covering them. On appeal, the Second District Court of Appeal reversed and remanded for the trial court to vacate Defendant’s conviction for lewd or lascivious molestation, concluding that double jeopardy prohibited convictions for both sexual battery and lewd or lascivious molestation in a single criminal episode. The Supreme Court quashed the decision of the Second District and remanded to the district court for an order affirming Defendant’s convictions, holding that Defendant’s convictions involved offenses of a separate character and type, which were distinct criminal acts that do no violate double jeopardy. View "State v. Drawdy" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder and one count of home invasion robbery with a firearm. The trial court sentenced Appellant to death for the murders and to life imprisonment for the armed home invasion robbery conviction. On appeal, Appellant raised thirteen claims of error. The Supreme Court affirmed, holding (1) most of Appellant’s claims of error were without merit; (2) a comment made by the prosecutor during penalty phase arguments was error, and the trial court erred in failing to assign a specific weight to the HAC aggravator, but the errors were harmless beyond a reasonable doubt; and (3) Appellant’s convictions were supported by competent, substantial evidence. View "Gonzalez v. State" on Justia Law

Appellant, a prisoner under sentence of death, was convicted of two counts of premeditated first-degree murder, among other crimes. After Governor Rick Scott signed a death warrant, Appellant filed a successive postconviction motion filed under Fla. R. Crim. P. 3.851, claiming that the trial court committed several substantive and procedural errors that denied him a fair and impartial trial and that the circuit court erred in limiting his ability to file additional successive motions. The Supreme Court affirmed the circuit court’s order denying relief on all of Appellant’s claims, holding that the claims were procedurally barred and without merit. View "Hendrix v. State" on Justia Law

Petitioner was convicted of numerous crimes and sentenced to life imprisonment. Petitioner’s convictions and sentences were affirmed on appeal. Petitioner subsequently filed several pro se filings in the Supreme Court and other courts. In this case, Petitioner filed a pro se petition for writ of habeas corpus challenging his convictions and sentences, which the Supreme Court dismissed. Because Petitioner’s petition contained false information and because he filed eleven extraordinary writ petitions with the Supreme Court since 2012, the Court found that the petition filed by Petitioner contained false information and was a frivolous proceeding and directed the clerk of court to reject any future pleadings or other requests for relief filed by Petitioner related to his convictions or sentences. View "Williams v. Crews" on Justia Law

Petitioner was convicted of kidnapping, robbery, aggravated battery, burglary, and possession of a firearm by a convicted felon. After his convictions and sentences became final, Petitioner filed numerous pro se filings in the Supreme Court and other courts. Petitioner later filed a pro se petition for writ of habeas corpus challenging his convictions and sentences. The Supreme Court dismissed the petition and expressly retained jurisdiction to pursue possible sanctions against Petitioner. Because Petitioner’s petition in this case contained false information and because Petitioner had filed eleven extraordinary writ petitions with the Supreme Court since 2012, the Court found that the petition filed in this case was a frivolous proceeding and imposed sanctions. View "Williams v. Crews" on Justia Law

Ann Aldrich died before having revised her will to dispose of an inheritance she received from her sister. Ann’s husband, James Aldrich, argued that the most appropriate construction of the will was that Ann intended for the property she had acquired from her sister to pass to him. Ann’s nieces disagreed with James’s construction of the will. The trial court entered summary judgment in favor of James pursuant to the purported authority of Fla. Stat. 732.6005(2), which provides that a will shall be construed to pass all property that the testator owned at death, including property acquired after the will is executed. The First District Court of Appeal reversed, concluding that section 732.6005(2) did not control because the disputed property was not alluded to in the will and, therefore, it was irrelevant whether it was acquired before or after the will was executed. The Supreme Court approved the decision of the First District, holding that section 732.6005 does not require construing a will as disposing of property not named or in any way described in the will, despite the absence of any residuary clause, or any other clause disposing of the property, where the decedent acquired the property in question after the will was executed. View "Aldrich v. Basile" on Justia Law

Plaintiff brought a personal injury action against Defendant for injuries Plaintiff sustained in an altercation that occurred when Plaintiff was at a bar with Defendant and Defendant’s friend, Russell Noordhoek. The jury returned a verdict for Plaintiff. The Third District Court of Appeal reversed and remanded for entry of a judgment for Defendant, holding that Defendant did not owe a duty of care to Plaintiff when Plaintiff was attacked by Noordhoek, and therefore, Defendant could not be held liable for Plaintiff’s injuries. The Supreme Court quashed the decision below, holding that the Third District erred when it concluded that the evidence failed to demonstrate that Defendant owed a legal duty of care to Plaintiff, and, under the specific facts of this case, Defendant’s duty of care extended to the misconduct of a third party, Noordhoek. View "Dorsey v. Reider" on Justia Law

In 1991, a group of flight attendants initiated a class action suit against several tobacco companies. The suit resulted in a settlement agreement. Subsequently, the Flight Attendant Medical Research Institute (FAMRI) was formed, and several of the flight attendants who were part of the class action became members of FAMRI’s board, including Patricia Young and Alani Blissard. Thereafter, several flight attendants filed individual suits against the tobacco companies. Steve Hunter and Philip Gerson were among the attorneys who represented the flight attendants. In 2010, a group of attorneys, including Gerson and Hunter, filed a petition against FAMRI on behalf of some of the flight attendants who were part of the original class, seeking an accounting of FAMRI’s funds and requesting that the settlement funds be dispersed directly to their clients. Young, Blissard and FAMRI moved to disqualify the attorneys on the ground of conflict of interest. The trial court entered an order disqualifying several attorneys, including Hunter and Gerson. The Third District Court of Appeals quashed the trial court’s order. The Supreme Court quashed the Third District’s decision and reinstated the trial court’s disqualification order, holding that disqualification was warranted in this case. View "Young v. Achenbauch" on Justia Law

After a jury trial, Defendant was convicted of three counts of sexual battery and one count each of kidnapping, aggravated battery, and attempted robbery. Defendant was sentenced to life imprisonment for each sexual battery count and the kidnapping count. Defendant appealed, arguing that the trial court abused its discretion in refusing to give a curative instruction relating to statements the prosecutor made during voir dire. The Second District Court of Appeals found that the prosecutor’s remarks were improper but that there was “no reasonable possibility that the failure to give a curative instruction affected the verdict.” The Supreme Court quashed the Second District’s decision, holding that the prosecutor impermissibly commended during voir dire on Defendant’s constitutional right to remain silent, and the comments were not harmless beyond a reasonable doubt. View "Marston v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and armed robbery with a firearm. Defendant was sentenced to death for the murder conviction. The Supreme Court (1) affirmed Defendant’s convictions, holding that the evidence was sufficient to support the verdicts of guilt; but (2) vacated the sentence of death, holding that a death sentence in this case was not proportionate to other cases in which the sentence of death has been upheld, and in fact, this case was indistinguishable from other cases involving the single aggravator of a murder during the commission of a robbery where the death penalty has been vacated. Remanded for imposition of a life sentence without the possibility of parole. View "Yacob v. State" on Justia Law