Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of second-degree murder and his sentence imposed for a Class B1 felony, holding that Defendant was not entitled to relief on his allegations of error.In 2012, the legislature amended North Carolina's murder statute to classify second-degree murders according to varying degrees of severity based on the level of culpability with which the criminal defendant acted. Under the amended statute, most kinds of second-degree murder are classified at the Class B1 felony level, but when it is determined that an offender acted with depraved-heart malice, second-degree murder is classified as a Class B2 felony. In 2019, Defendant was convicted of second-degree murder. At issue was whether Defendant should have been sentenced at the lower B2 felony level, instead of at the class B1 felony level, because the jury concluded that he acted with depraved-heart malice. The Supreme Court affirmed Defendant's sentence, holding that, under the circumstances, the trial court properly sentenced Defendant at the class B1 level because the jury's completed verdict form was not ambiguous. View "Furst v. Rebholz" on Justia Law

The Supreme Court found that Petitioner, who filed a pro se petition for a writ of habeas corpus, failed to show cause why he should not be barred and sanctioned him as set forth in this opinion.Petitioner was convicted of one count of armed robbery with a non-deadly weapon and sentenced to life imprisonment. Including this Petitioner, Petitioner had filed fourteen pro se petitions with the Supreme Court, including the habeas corpus petition at issue. The Supreme Court denied the petition, concluding that the petition was a frivolous proceeding, and directed the clerk of court to reject any future pleadings or other requests for relief submitted by Petitioner, holding that if no action is taken, Petitioner will continue to burden the Supreme Court's resources. View "Green v. Dixon" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's successive postconviction motion filed under Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief on his allegations of error.Appellant was convicted of armed robbery and first-degree murder and was sentenced to death. The Supreme Court affirmed. Appellant later filed the successive motion at issue here seeking vacatur of his death sentence based on allegedly newly-discovered evidence. The trial court concluded that the motion was untimely and then ruled on the merits that the claims did not warrant relief. The Supreme Court affirmed, holding that the circuit court committed no error in summarily denying Appellant's claims. View "Sanchez-Torres v. State" on Justia Law

The Supreme Court held that Petitioner, who was ordered to show cause why she should not be further sanctioned and barred from filing any pro se pleadings in the Supreme Court, had abused the Court's limited judicial resources and directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner, unless such filings were signed by a member in good standing of The Florida Bar. The Court further denied any pending motions or requests for relief, holding that based on Petitioner's history of filing pro se petitions and requests for relief that were meritless or otherwise inappropriate for appellate review, Petitioner failed to show cause why she should not be sanctioned. View "A.C. v. Dep't of Children & Families" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's latest successive postconviction motion seeking relief under Hall v. Florida, 572 U.S. 701 (2014), holding that Appellant did not get the benefit of Hall.Defendant was found guilty of two counts of first-degree murder and other crimes and sentenced to death. Defendant challenged his death sentence numerous times. Here, Defendant raised a second intellectual disability claim relying on Hall v. Florida, 472 U.S. 701 (2014). The circuit court summarily denied the claim. The Supreme Court reversed and remanded for an evidentiary hearing. After a hearing, the circuit court denied the motion. The Supreme Court affirmed on the basis that Hall was not retroactive, and therefore, his Hall-based intellectual disability claim failed regardless of the evidence presented at his evidentiary hearing. View "Walls v. State" on Justia Law

The Supreme Court affirmed the decision of the circuit court summarily denying Donald David Dillbeck's fourth successive postconviction motion filed under Fla. R. Crim. P. 3.851, denied Dillbeck's habeas petition, and denied two additional motions filed by Defendant, holding that Defendant was not entitled to relief in any form.Dillbeck twice committed murder and sat on death row for several decades. On January 23, 2023 Governor Ron DeSantis signed Dillbeck's death warrant. Dillbeck then filed his fourth successive postconviction motion, arguing that he was exempt from execution on three grounds. The circuit court summarily denied all three claims. Dillbeck appealed, petitioned the Supreme Court for a writ of habeas corpus, moved for a stay of execution, and requested oral argument. The Supreme Court denied all forms of relief, holding that Dillbeck failed to prove any of his allegations of error. View "Dillbeck v. State" on Justia Law

The Supreme Court approved the decision of the Second District Court of Appeal in the proceedings below, holding that an appraiser cannot be "disinterested" if he or she, or a firm in which he or she has an interest, is to be compensated for services as a public adjuster with a contingency fee.At issue was whether George Keys, the president of Keys Claims Consultants, Inc. (KCC), a homeowner's public adjusting firm, which was to be compensated on a contingency basis for its adjusting services, could subsequently serve as a "disinterested" appraiser for Jon Parrish under the language of the relevant insurance policy with State Farm. The trial court concluded that Keys could serve as Parrish's disinterested appraiser because the two had disclosed their arrangement to State Farm. The Second District reversed, concluding that Keys could not serve as Parrish's disinterested appraiser. The Supreme Court affirmed, holding that because Keys’s company, KCC, was to be compensated via contingency fee, Keys had a pecuniary interest in the outcome of the claim and could not qualify as a “disinterested” appraiser. View "Parrish v. State Farm Fla. Insurance Co." on Justia Law

The Supreme Court denied Petitioner's writ of mandamus, which the Supreme Court created as a motion for written opinion, as well as any other pending motions or requests for relief, holding that holding that Petitioner was not entitled to relief and had abused the Court's resources.As of the date of this opinion, Petitioner had filed forty-one pro se petitions or notices with the Court since August 29, 2022. The Supreme Court denied the instant petition and ordered Petitioner to show cause why she should not be barred from filing further pro se requests for relief. The Supreme Court then concluded that Petitioner failed to show cause why she should not be sanctioned and directed the Clerk of Court to reject any future pleadings or requests for relief unless such filings were signed by a member in good standing of The Florida Bar. View "A.C. v. Dep't of Children and Families" on Justia Law

The Supreme Court held that neither the common law doctrine of legislative immunity nor of governmental function immunity prohibited the statutory civil actions and penalties imposed against local governments and officials for certain violations of the firearms preemption statute, Fla. Stat. 790.33.Petitioners brought suit seeking a declaration from the circuit court that sections 790.33(3)(c),(d) and (f) were invalid because sections 790.33(3)(c) and (d) violated legislative immunity and that section 790.33(3)(f) violated governmental function immunity. The circuit court invalidated the challenged provisions. The court of appeal reversed, holding that the statutory penalty provisions at issue in this case were valid and enforceable. The Supreme Court affirmed, holding that neither legislative immunity nor governmental function immunity prohibited the statutory actions and penalties in section 790.33(3)(c), (d), or (f). View "Fried v. State" on Justia Law

In this wrongful death action, the Supreme Court approved the decision of the Fifth District Court of Appeal reversing as excessive a punitive damages award that exceeded the net compensatory damages award by a ratio of 106.7 to 1, holding that the trial court abused its discretion by denying remittitur of the excessive award.The Fifth District certified to the Supreme Court the question of whether a trial court in a wrongful death action abuses its discretion by denying remittitur of a punitive damages award "that does not bear a reasonable relation to the amount of damages proved and the injury suffered by the statutory beneficiaries." The Supreme Court answered the question in the positive and held that the trial court improperly denied remittitur of the excessive award because no reasonable trial court could have concluded that the necessary relation existed in this case. View "Coates v. R.J. Reynolds Tobacco Co." on Justia Law