Justia Florida Supreme Court Opinion Summaries

Petitioner, a California resident, was sexually assaulted while vacationing in Mexico. The assault occurred while Petitioner received a complimentary massage in exchange for her attendance at a resort's timeshare presentation. Petitioner sued the resort, a corporation with its primary place of business in Florida, (the Florida Defendants) for negligent vacation packaging. The Florida Defendants filed a motion to dismiss based on forum non conveniens, arguing that Mexico would be a more convenient forum. The trial court granted the motion. The court of appeal affirmed. The Supreme Court quashed the court of appeal's decision, holding that the court misapplied the forum non conveniens analysis, particularly by failing to afford a strong presumption in favor of Plaintiff's initial choice of an otherwise proper forum. View "Cortez v. Palace Resorts, Inc." on Justia Law

Plaintiff, individually and in her capacity as the personal representative of the estate of Lance Ruble, sought to amend the original complaint filed in this action before Respondents served an answer to that complaint. The trial court dismissed Plaintiff's amended complaint, and the court of appeal affirmed. The Supreme Court reversed based on its holding in Capone v. Phillip Morris USA, Inc. (Capone II) and Boca Burger, Inc. v. Forum, holding (1) when an injured Plaintiff in a personal injury action dies, the personal representative of the decedent's estate is not required to file a separate wrongful death action but may be added as a party to the pending action and thus may file an amended pleading that alleges new claims and causes of action; and (2) the right of a plaintiff under Fla. R. Civ. P. 1.190(a) to amend a complaint once before the service of a responsive pleading is absolute, and a trial court has no discretion to deny that amendment. Remanded. View "Ruble v. Rinker Material Corp." on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and aggravated battery. The trial court sentenced Defendant to death for the murder. The Supreme Court affirmed Defendant's convictions and sentences, holding (1) the trial court did not abuse its discretion in admitting evidence of text messages sent from Appellant's cell phone to the victims; (2) the trial court did not err in finding that the murder was cold, calculated, and premeditated; (3) the trial court did not abuse its discretion in giving great weight to the finding that the murder was especially heinous, atrocious, or cruel; (4) the death sentence was proportionate in this case; (5) Florida's capital sentencing scheme does not violate Ring v. Arizona; and (6) competent, substantial evidence supported the jury's finding of first-degree murder beyond a reasonable doubt. View "Jean-Philippe v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. Defendant appealed, contending, among other things, that the trial court erred when it denied his motion to suppress his confession because, during his interrogation and before he confessed to the murder, he invoked his right to remain silent. The Supreme Court reversed the conviction and remanded for a new trial, holding (1) based on the totality of the circumstances, the police did not scrupulously honor Defendant's invocation of his right to remain silent; (2) there was not competent, substantial evidence supporting the trial court's finding that Defendant's confession was voluntary; and (3) this error was not harmless beyond a reasonable doubt. View "Deviney v. State" on Justia Law

Frank and Karen Capone filed an action against Philip Morris USA, a tobacco manufacturer, alleging several claims. After Frank died, Karen, in her capacity as personal representative of Frank's estate, sought to amend the complaint to add a wrongful death claim. Karen also filed a motion to substitute herself as a party plaintiff. The circuit court denied Karen's motions and dismissed the entire action, concluding that the personal injury action in this case could not be amended to include a wrongful death action. Although the circuit court, upon reconsideration, granted Karen's previously-filed motions, it vacated that order, finding Karen's motion for reconsideration was not timely served. The court of appeal affirmed, holding that the original personal injury action filed by the Capones could not be amended after Frank's death to include a wrongful death claim. The Supreme Court quashed the decision of the Third District, holding that upon the death of a party plaintiff in a personal injury action, the personal representative of the decedent's estate may be added to the pending action as a party and thus may file an amended pleading that alleges new or amended claims and causes of action. Remanded. View "Capone v. Philip Morris USA, Inc." on Justia Law

The State charged Defendant with two drug-related offenses. Defendant rejected a twelve-year plea offer after being incorrectly advised that his maximum sentence was thirty years when, in fact, Defendant faced a maximum sentence of life in prison. After trial, Defendant was found guilty of simple sale of cocaine and possession of cocaine and was sentenced to thirty years imprisonment. The court of appeal affirmed, concluding that Defendant could not show prejudice because he ultimately received the same sentence as what he was incorrectly advised. Subsequent to the court of appeal's decision, the U.S. Supreme Court issued two decisions - Missouri v. Frye and Lafler v. Cooper - concerning ineffective assistance of counsel claims in which the defendant rejected a pea offer based on misadvice. In light of these two cases, the Florida Supreme Court receded from its decisions in Cottle v. State and Morgan v. State with respect to what a defendant must show in order to demonstrate prejudice. After clarifying what a defendant must show to demonstrate prejudice, the Court quashed the court of appeal's decision because it incorrectly analyzed the prejudice prong. Remanded. View "Alcorn v. State" on Justia Law

After a jury trial, Petitioner was convicted of first-degree murder under both premeditated and felony-murder theories. The trial court sentenced Petitioner to death. The Supreme Court affirmed Petitioner's conviction and sentence. Petitioner subsequently filed several motions for postconviction relief. This appeal concerned the denial of Petitioner's third successive motion for postconviction relief and a motion to vacate his death sentence or, in the alternative, a motion for an evidentiary hearing. Petitioner also filed a fifth state petition for writ of habeas corpus. The Supreme Court affirmed the circuit court's order dismissing Petitioner's motions, holding (1) Petitioner's claim of newly discovered evidence was without merit; (2) Petitioner's claim regarding his counsel on direct appeal was procedurally barred and without merit; and (3) Petitioner's claim of ineffective assistance of trial counsel during the penalty phase was procedurally barred. View "Van Poyck v. State" on Justia Law

After a jury trial, Defendant was convicted of burglary of a dwelling with an assault or battery, robbery with a firearm, and related offenses. Defendant appealed, challenging the admission of a witness's written statement as past recollection. Specifically, Defendant contended that a basic requirement for admission was not met because the witness did not testify to the accuracy or truthfulness of the statement. The court of appeal affirmed Defendant's convictions and sentences, holding that, under the circumstances, there was sufficient evidence to lay a foundation for admission of the witness's statement under Fla. Stat. 90.803(5) even though the witness did not confirm the accuracy of the statement at trial. The Supreme Court quashed the decision of the court of appeal, holding (1) pursuant to section 90.803(5), one of the requirements for admission of past recollection recorded hearsay is that the witness who made the statement vouch for the accuracy of the record or memorandum when the evidence is offered; and (2) in this case, a proper foundation for admission of the witness's statement of past recollection recorded was not established. Remanded. View "Polite v. State" on Justia Law

After a jury trial in 2009, Defendant was convicted of second-degree murder and sentenced to life in prison. Defendant appealed, arguing that the trial court erred by instructing the jury on manslaughter by act and that the error was fundamental. The Second District Court of Appeal affirmed Defendant's conviction and sentence, concluding that the 2008 manslaughter by act instruction did not include an intent-to-kill element, which the Supreme Court found fundamentally erroneous in State v. Montgomery. However, the Second District certified that its decision conflicted with the with the decision of the First District in Riesel v. State. The Supreme Court quashed the decision of the Second District and approved the decision of the First District in Riesel, holding (1) the 2008 standard instruction for manslaughter by act erroneously required the jury to find Defendant intended to cause the death of the victim; and (2) the trial court fundamentally erred in giving the 2008 standard jury instruction in this case. Remanded for a new trial. View "Daniels v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and robbery with a deadly weapon. The trial court imposed a sentence of death. Defendant subsequently filed a postconviction motion, which was denied. Defendant appealed the denial of his motion and also filed a petition for writ of habeas corpus asserting ineffective assistance of appellate counsel. The Supreme Court affirmed, holding (1) the trial court did not err in finding Defendant's trial counsel was not ineffective for (i) deciding not to present the testimony of a mental health expert in the penalty phase to establish mental mitigation, (ii) failing to move for a change of venue, and (iii) failing to object to certain prosecutorial comments during the guilt phase closing argument; (2) Florida's capital sentencing scheme is constitutional; and (3) Defendant was not prejudiced by appellate counsel's failure to argue on direct appeal that the trial court improperly failed to assign weight to each mitigator and evaluate the relative weights of the aggravating and mitigating factors in its sentencing order. View "Taylor v. State" on Justia Law