Justia Florida Supreme Court Opinion Summaries

Petitioner was a juvenile charged as an adult with attempted first-degree murder with a deadly weapon. After the U.S. Supreme Court issued its decision in Graham v. Florida, Petitioner filed a motion to have a bond set. The trial court denied the motion. Petitioner filed a second petition for writ of habeas corpus, arguing (1) the Florida Constitution provides for pretrial release as a matter of right for a noncapital offense or an offense that does not carry the possibility of a life sentence, and (2) because Graham prohibits the State from sentencing him to life without an opportunity for parole, he was entitled to bond under the provisions of the State Constitution. The court of appeal denied the petition, concluding that Graham does not impact a juvenile defendant's entitlement to bond because the Florida Constitution considers only the classification of the offense, not a defendant's eventual sentence. The Supreme Court quashed the decision below, holding that juvenile offenders such as Petitioner were entitled to bond under the Florida Constitution because they cannot be charged with a crime punishable by life imprisonment under Florida's current statutory scheme and Graham. View "Treacy v. Lamberti" on Justia Law

This was the second time this case was before the Supreme Court. In the Court's previous decision, the Court quashed the court of appeal's decision, holding that the trial court should have granted Defendant's motion to suppress evidence obtained from a search of Defendant's truck, holding that law enforcement officers lacked probable cause where "the fact that a drug-detection dog has been trained and certified to detect narcotics, standing alone, is not sufficient to demonstrate the reliability of the dog." The U.S. Supreme Court reversed, holding that because the training records established the dog's reliability in detecting drugs in this case, and because Defendant failed to undermine that showing, the police officer had probable cause to search Defendant's truck. On remand, the Florida Supreme Court withdrew its prior opinion and approved of the court of appeal's decision in Harris I. View "Harris v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder and burglary. Defendant appealed, alleging that the trial court's failure to remove a prospective juror for cause resulted in a denial of his right to a fair and impartial jury as guaranteed by the state and federal constitutions. The court of appeal affirmed, concluding that the juror was competent to serve. The Supreme Court quashed the decision of the third district and remanded for a new trial, holding that the juror demonstrated during voir dire that she could not fulfill her role as a fair and impartial arbiter and thus should have been excused for cause. View "Matarranz v. State" on Justia Law

After a jury trial, Defendant was convicted of burglary of a dwelling with an assault or battery with a dangerous weapon, robbery with a weapon, and carjacking with a dangerous weapon. The court of appeal affirmed Defendant's convictions for burglary of a dwelling and carjacking but certified conflict on the issues of (1) whether Florida's burglary statute requires a structure to be suitable for habitation on the date of the offense for the structure to meet the definition of a dwelling, and (2) whether a defendant can be convicted of carjacking where the force used in the robbery on the inside of the building is separate from the taking of the vehicle on the outside of the building. The Supreme Court affirmed the court of appeal, holding (1) a structure undergoing substantial renovations constitutes a "dwelling" under the relevant statute; and (2) Defendant's actions constituted a carjacking under the relevant statute. View "Young v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder, two counts of robbery, and two counts of kidnapping. The trial court sentenced Defendant to concurrent sentences of death for both murders. The Supreme Court affirmed the convictions and sentences of death. Defendant subsequently filed a motion for postconviction relief, alleging that his trial counsel provided ineffective assistance. The postconviction court denied all of Defendant's claims. The Supreme Court affirmed the denial of relief and denied Defendant's petition for a writ of habeas corpus, holding (1) trial counsel did not provide constitutionally defective assistance; (2) Florida's death sentencing scheme is constitutional; and (3) Defendant's appellate counsel did not provide ineffective assistance. View "Jackson v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed the first-degree murder conviction and death sentence, holding (1) the trial court did not err in finding a cold, calculated and premeditated aggravator; (2) Defendant's death sentence was proportionate; (3) the penalty-phase jury instructions did not violate Caldwell v. Mississippi, and Ring v. Arizona did not require the reversal of Defendant's death sentence; (5) the trial court did not err in refusing to permit Defendant to present guilt-phase evidence of his mental condition at the time of the murder; and (6) competent, substantial evidence supported the verdict beyond a reasonable doubt. View "Brown v. State" on Justia Law

Petitioner, convicted of first-degree murder of a state correctional officer, appealed an order of the circuit court denying his motion to vacate his death sentence under Florida Rule of Criminal Procedure 3.851 and petitioned for a writ of habeas corpus. The court rejected petitioner's claim of ineffective assistance of trial counsel, concluding that it was reasonable for trial counsel to not challenge the intended sexual battery evidence on undue prejudice grounds and the court's confidence in the trial court's conclusion was not undermined by the possibility of additional evidence about the effect of petitioner's childhood on his mental status. The court also concluded that, because petitioner's challenges to Florida's death penalty scheme were meritless, appellate counsel did not err by failing to raise the arguments on direct appeal and petitioner was not entitled to habeas relief. Accordingly, the court affirmed the denial of postconviction relief and denied the petition for a writ of habeas corpus. View "Smith v. State" on Justia Law

Defendant appealed his conviction for first-degree murder and sentenced of death. On appeal, defendant raised eighteen claims of error and the State raised a claim regarding the proportionality of the death sentence in this case. The court concluded that defendant's claims were without merit, with the exception of Issue 2 regarding the scope of cross-examination. However, the court concluded that this error was harmless. The court also concluded that the death sentence was proportionally warranted in this case. Accordingly, the court affirmed the conviction and sentence. View "Gosciminski v. State" on Justia Law

Plaintiffs sued defendant, seeking recovery for injuries allegedly sustained in an automobile collision. This case concerned the proper standard of review and the appropriate remedy when an appellate court reviewed a trial court's order granting a new trial on the ground that the jury verdict was contrary to the manifest weight of the evidence, where the trial court's order was premised, at least in part, on an error of law. The court held that an appellate court properly applied a de novo standard of review to a trial court's conclusions of law in an order granting a new trial based on the manifest weight of the evidence, giving no deference to the trial court's legal conclusions. Although a trial court's conclusions of law were not entitled to deference, its findings of facts and determinations of credibility were still entitled to deference because of the trial court's superior vantage point of having been present during the entire trial. Although the court concluded that the First District was correct in reversing the trial court's order, the court quashed the First District's decision because it concluded that reinstatement of the jury verdict was not the proper remedy in this case. Accordingly, the court remanded for reconsideration. View "Van, Sr., et ux., v. Schmidt" on Justia Law

Defendant was charged with burglary, grand theft, dealing in stolen property, and providing false information to a pawnbroker. The trial court refused to refer to Fla. Stat. 812.025 in its jury instructions or otherwise instruct the jury that it was precluded from finding Defendant guilty of both dealing in stolen property and theft. Defendant was convicted of all of the charges, but the trial judge subsequently dismissed the grand theft conviction. Defendant appealed, arguing that he was entitled to a new trial because the trial court denied his requested instruction modeled on section 812.025. The court of appeal affirmed. The Supreme Court quashed the decision of the court of appeal, holding (1) a trial court must instruct the jury pursuant to section 812.025 when both theft and dealing in stolen property offenses are submitted to the jury; (2) if a trial court denies a defendant's request for a jury instruction under section 812.025, the defendant must be given a new trial if the jury convicts the defendant of both theft and dealing in stolen property; and (3) Defendant was entitled to a new trial on the dealing in stolen property and grand theft counts. View "Williams v. State" on Justia Law