Justia Florida Supreme Court Opinion Summaries

Defendant was convicted of first-degree murder and sentenced to death. With a minor exception, the Supreme Court denied Defendant's requests for postconviction relief and his petitions for writs of habeas corpus. In this postconviction action, Defendant filed a motion requesting postconviction DNA testing on six items collected by law enforcement in connection with the investigation of the victim's murder. Of these items, the State was only able to locate one of them. The circuit court summarily denied Defendant's motion. The Supreme Court affirmed, holding that there was no reasonable probability that Defendant would have been acquitted or received a lesser sentence if DNA evidence from any of the requested items had they been admitted at his trial. View "Jackson v. State" on Justia Law

Compass Construction and First Baptist Church were named as defendants in an action arising from a construction accident. Ultimately, First Baptist prevailed against the plaintiff in the main action and on its cross-claim for indemnity against Compass. First Baptist was awarded attorneys fees as part of its indemnity claim, but the parties disagreed about the appropriate hourly rate at which the fee for First Baptist's attorney should be calculated. In the main action, First Baptist's insurance company assigned an attorney to represent First Baptist. The attorney had a written fee agreement with the insurance company providing that attorney would be paid $170 per hour. In an alternative fee recovery clause, however, the agreement provided that if anyone other than the insurance company was required to pay attorney's fees, the attorney's hourly rate would be $300. The trial court calculated the award at the higher rate. The court of appeal reversed. The Supreme Court reversed, holding that the alternative fee recovery clause was valid. Remanded for reinstatement of the judgment awarding attorney's fees. View "First Baptist Church of Cape Coral, Fla., Inc. v. Compass Constr., Inc." on Justia Law

Defendant pled guilty to several crimes, including grand theft and first-degree felony murder. The trial court imposed the death sentence. The Supreme Court affirmed Defendant's convictions but vacated his sentence and remanded for a new penalty phase. On remand, the trial court again sentenced Defendant to death. The Supreme Court affirmed. Defendant subsequently filed an amended motion for postconviction relief, which the trial court denied after a hearing. Defendant appealed and filed a petition for writ of habeas corpus. The Supreme Court affirmed, holding, inter alia, (1) Defendant failed to show his counsel was constitutionally deficient; (2) the postconviction court did not abuse its discretion in denying Defendant's motion to disqualify the postconviction court's judge; and (3) appellate counsel provided effective assistance. View "Farr v. State" on Justia Law

Two decisions of the Third District Court of Appeal were before the Supreme Court here. In the first case (Public Defender), the Public Defender for the Eleventh Judicial Circuit filed motions in several criminal cases seeking to be relieved of the obligations to represent indigent defendants in non-capital felony cases. The trial court permitted the Public Defender to decline appointments in future third-degree felony cases. The court of appeal reversed. In the second case (Bowens), an assistant public defender filed a motion to withdraw from representing a defendant, alleging that his excessive caseload created a conflict of interest. The circuit court granted the motion, but the court of appeal reversed. The Supreme Court (1) quashed the court of appeal's decision in Public Defender and remanded, holding (i) aggregate/systemic motions to withdraw are appropriate where there is an office-wide or widespread problem as to effective representation, and (ii) the Public Defender demonstrated cause for withdrawal in this case; and (2) quashed in part and affirmed in part the decision in Bowens, holding that Fla. Stat. 27.5303(1)(d) is facially constitutional but should not preclude a public defender from filing a motion to withdraw based on excessive caseload or underfunding that would result in ineffective representation of indigent clients. View "Public Defender, Eleventh Judicial Circuit of Fla. v. State" on Justia Law

Child was born with birth-related neurological injuries. Child's parents (Petitioners) filed a claim for compensation under the Florida Birth-Related Neurological Injury Compensation Plan. The Florida Birth-Related Neurological Injury Compensation Association agreed to pay parental compensation of $100,000 to both parents jointly under Fla. Stat. 766.31(1)(b)(1), which provides for an award not exceeding $100,000 to the parents or legal guardians of an infant found to have sustained a birth-related neurological injury. Petitioners reserved the right to have a hearing before an ALJ to raise the issue of the interpretation and constitutionality of section 766.31(1)(b)(1). The ALJ denied Petitioners' claim for an additional $100,000 as part of the parental award, finding that the Legislature clearly intended that the maximum award of $100,000 was for both parents, not for each parent. The district court upheld the ALJ's judgment and denied each of Petitioners' constitutional claims. The Supreme Court approved the district court's decision, holding that the parental award provision (1) unambiguously provides for only a single award of $100,000; (2) does not violate equal protection; and (3) neither is void for vagueness nor unconstitutionally limits the right of access to courts. View "Samples v. Fla. Birth Related Neurological Injury Comp. Ass'n" on Justia Law

Petitioner Raymond James Financial Services required its clients (the investors) to sign an agreement to arbitrate all disputes arising out of the handling of their investments. At issue in this case was whether Florida's statute of limitations that is applicable to a "civil action or proceeding" applies to arbitration proceedings. In 2005, the investors filed a joint claim for arbitration against Raymond James, alleging federal and state securities violations and negligent supervision. The investors filed an action in state court seeking a declaration that the statute of limitations applied only to judicial actions and thus did not limit the time in which to bring their arbitration claims. The trial court granted declaratory judgment in favor of the investors. The court of appeal affirmed. The Supreme Court concluded that the investors' arbitration claims in this case were barred by the statute of limitations, holding that Florida's statute of limitations applies to arbitration because an arbitration proceeding is within the statutory term "civil action or proceeding" found in Fla. Stat. 95.011. View "Raymond James Fin. Servs., Inc. v. Phillips" on Justia Law

Defendant pleaded guilty to two counts of first-degree murder and was sentenced to death in 1998 on both murder counts. The Supreme Court affirmed Defendant's convictions and death sentences. Defendant subsequently filed a postconviction motion and a number of amended motions. Defendant also filed a motion to withdraw his guilty plea. In 2008, the trial court granted Defendant a new penalty phase proceeding based on the claim of ineffective assistance of counsel during the penalty phase but denied the remaining claims and Defendant's motion to withdraw his guilty plea. Defendant appealed and also petitioned the Supreme Court for a writ of habeas corpus, claiming his death sentence was disparate and disproportionate based on newly discovered evidence. The Supreme Court (1) affirmed the trial court's order denying relief on the claims relating to Defendant's guilty plea and an alleged Brady violation and granting relief on the claim of ineffective assistance of counsel in the penalty phase; and (2) denied Defendant's petition for habeas relief, holding that the claim in the petition should have been raised in the postconviction motion at the trial court and was therefore procedurally barred. View "Griffin v. State" on Justia Law

In this case the Supreme Court considered whether a municipal ordinance may validly establish superpriority status for municipal code enforcement liens. The court of appeal concluded that such an ordinance superpriority provision was invalid because it conflicted with a state statute and that the City's lien accordingly did not have priority over the lien of Wells Fargo's mortgage that was recorded before the City's lien was recorded. The City appealed, arguing that the ordinance superpriority provision within the "broad home rule powers" of the City. The Supreme Court accepted certification and concluded that the court of appeal correctly decided the ordinance superpriority provision was invalid because it conflicted with state law. View "City of Palm Bay v. Wells Fargo, N.A." on Justia Law

Defendant was convicted of first-degree murder and sexual battery and sentenced to death. The Supreme Court affirmed Defendant's convictions and death sentence on direct appeal. Defendant subsequently filed a several post-conviction motions, which were ultimately unsuccessful. After the governor set a date for Defendant's execution, Defendant filed a successive postconviction motion, raising four claims. The circuit court summarily denied relief on all claims. The Supreme Court affirmed, holding (1) Defendant's claim that his mental illness should exempt him from execution was untimely and procedurally barred; (2) Defendant's claim that the death warrant selection process was arbitrary, thus rendering the death penalty unconstitutional, was without merit; (3) Defendant's claim that the clemency process he received was conducted in an arbitrary and capricious manner was without merit; and (4) Defendant's claim that adding execution to the "inordinate length of time" he spent on death row would constitute cruel and unusual punishment was without merit. View "Carroll v. State" on Justia Law

After a jury trial, Defendant was convicted of the 2001 first-degree murder of his wife. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant's conviction and sentence. Defendant subsequently filed a motion for postconviction relief, raising several claims. The circuit court denied relief. The Supreme Court affirmed, holding that the postconviction court correctly denied relief on Defendant's claims of ineffective assistance of trial counsel, as (1) counsel's failure to investigate and present evidence that Defendant had organic brain damage did not undermine confidence in the sentence; (2) counsel was not constitutionally deficient regarding the child witnesses who testified at Defendant's trial; and (3) counsel's failure to present evidence regarding the registration of the gun used in the homicide did not undermine confidence in Defendant's sentence; and (4) counsel made a reasonable strategic decision to have Defendant wear jail clothing during the penalty phase. View "Rodgers v. State" on Justia Law