Justia Florida Supreme Court Opinion Summaries

After Defendant, an inmate, committed several sexual offenses in Florida and Georgia, the state attorney initiated civil commitment proceedings against him under the Jimmy Ryce Act. Almost four years later, Defendant, who was still in custody, filed a motion to dismiss the commitment petition, arguing that he was not in lawful custody at the time commitment proceedings were initiated because his sentence had expired due to postconviction credit for time previously served. The circuit court denied the motion to dismiss based on its determination that Defendant was in lawful custody when commitment proceedings were initiated. The district court dismissed the commitment petition and ordered the immediate release of Defendant from custody, concluding that the circuit court did not have jurisdiction to adjudicate the commitment petition because Defendant was not in lawful custody when the State initiated commitment proceedings. The Supreme Court approved the district court's decision, holding that Defendant was not in lawful custody at the time the commitment procedures were initiated because his incarcerative sentence had already expired. View "State v. Phillips" on Justia Law

Law Firm, located in Virginia, leased a vehicle from Company. Tortfeasor, who was driving the car with permission by Law Firm, collided with a car driven by Plaintiff. The day before the accident, the insurance policy on the vehicle lapsed for nonpayment. Plaintiff filed suit in Florida against Law Firm, Tortfeasor, and Company, alleging that because Company had failed to comply with the insurance requirements of Fla. Stat. 324.021(9)(b)(1), Company was vicariously liable for Tortfeasor's negligent operation of the car under Florida's dangerous instrumentality doctrine. Company moved for summary judgment, contending that its liability should be based on Virginia tort law and that if Florida law applied, section 342.021(9)(b)(1) was preempted by the Graves Amendment, a federal law providing that the owner of a motor vehicle who leases the vehicle shall not be vicariously liable from harm that results from the operation of the vehicle during the lease. The trial court concluded that Florida law applied but that the Graves Amendment did preempt section 324.021(9)(b)(1). The court of appeal affirmed. The Supreme Court approved the decision, holding that the Graves Amendment preempts section 324.021(9)(b)(1). View "Rosado v. Daimlerchrysler Fin. Servs. Trust" on Justia Law

Defendant was convicted and sentenced to death for the kidnapping and murder of a ten-year-old. The Supreme Court affirmed Defendant's conviction on direct appeal but remanded for resentencing. After resentencing, when Defendant was again sentenced to death, the Supreme Court affirmed Defendant's sentence. Defendant filed several postconviction motions, which were denied. Defendant filed the instant motion to vacate sentence and requested certain public records after his execution date was set. The circuit court summarily denied relief on all claims. Defendant appealed and filed a petition for a writ of habeas corpus. The Supreme Court affirmed and denied habeas corpus relief, holding (1) the majority of Defendant's claims were without merit; (2) the circuit court properly denied Defendant's records requests because the requested records were not relevant to a colorable claim; and (3) Defendant's petition for habeas corpus was untimely. View "Mann v. State" on Justia Law

EB Acquisitions I (EB) entered into a written contract to purchase real property from DK Arena. The parties orally agreed to modify their contract for the sale of the property by extending the due diligence deadline. After the original due diligence period expired, EB attempted to terminate the contract of sale and sought a return of its deposit. DK Arena filed suit alleging breach of contract. EB asserted several counterclaims, including breach of contract. The trial court held in favor of EB on all claims, concluding that the oral agreement was valid and enforceable, notwithstanding the Statute of Frauds, under the doctrine of promissory estoppel. The court ruled that EB retained an unqualified right to terminate the contract and obtain the return of its deposit. The Supreme Court quashed the decision of the district court to the extent it was inconsistent with this opinion, holding that the district court applied an improper estoppel exception to the Statute of Frauds in express and direct conflict with the Court's decision in Tanenbaum v. Biscayne Osteopathic Hospital, Inc. Remanded. View "DK Arena, Inc. v. EB Acquisitions I, LLC" on Justia Law

Defendant was convicted of attempted murder, among other crimes, and was sentenced to various terms of imprisonment, including a fifty-five-year term. Defendant's convictions and sentences were affirmed on appeal. After unsuccessfully making a number of filings in the Supreme Court challenging his convictions and sentences, Defendant filed a pro se petition for writ of mandamus with the Court. Because the petition filed in this case was without merit, and because Defendant submitted multiple other meritless filings seeking relief relating to his criminal case that demonstrated an ongoing pattern of abuse of the judicial process, the Court (1) instructed the clerk of court to reject any filings submitted by Defendant relating to his criminal court case; and (2) found Defendant's current petition to be frivolous and directed the clerk of court to forward a copy of this opinion to the Department of Corrections' institution or facility where Defendant was incarcerated. View "Nelson v. Crews" on Justia Law

Defendant was convicted of robbery and murder and was sentenced to death. Based on newly discovered evidence, Defendant's counsel filed a postconviction motion. After an evidentiary hearing, counsel filed a motion for reimbursement of counsel, also requesting that the court issue an order directing the payment of his investigative fees. The chief judge of the judicial circuit denied the motion for reimbursement based on the fact that the expenses exceeded the statutory cap for investigative expenses by $1,844. The Supreme Court reversed, holding (1) the trial court improperly focused on whether this was an "ordinary" capital case, as opposed to reviewing whether there were "extraordinary or unusual circumstances" that required defense counsel to exceed the statutory cap for investigative expenses; and (2) based on the record, counsel's actions and the expenses incurred were reasonable and necessary, and the case presented "extraordinary or unusual circumstances" that required defense counsel to exceed the statutory cap for investigative services. View "McClain v. Circuit Court" on Justia Law

After a jury trial, Defendant was convicted of kidnapping and first-degree murder. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant's convictions and sentence, holding (1) the trial judge did not err in admitting statements Defendant made to law enforcement because the statements did not constitute similar fact or collateral crime evidence and were otherwise relevant and admissible to establish premeditation; (2) because Defendant's expert testimony opened the door for a witness to testify about allegations of Defendant's past criminal conduct, the trial court properly admitted the testimony and properly excluded the witness from the sequestration rule; (3) substantial, competent evidence supported the trial court's fining that certain aggravating circumstances applied in Defendant's case; (4) the trial court properly rejected the lack of capacity mitigating factor; (5) the evidence was sufficient to support the convictions; and (6) the imposition of the death sentence in this case was proportionate when compared to other death sentences the Court has upheld. View "Hilton v. State" on Justia Law

Defendant was convicted of first-degree murder and kidnapping and sentenced to death for the first-degree murder and to fifteen years' imprisonment for kidnapping. The Supreme Court affirmed on direct appeal. Defendant subsequently filed a motion for postconviction relief. Following an evidentiary hearing, the circuit court denied postconviction relief on all claims. Defendant appealed the circuit court's denial of postconviction relief and also petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of Defendant's postconviction motion and denied his habeas petition, holding (1) the circuit court did not err in concluding that Defendant's postconviction claims were either procedurally barred, conclusively refuted by the record, facially or legally insufficient as alleged, or without merit as a matter of law; and (2) Defendant's counsel provided effective assistance, and therefore, Defendant's claims for habeas relief failed. View "Conahan v. State" on Justia Law

Plaintiff, the personal representative of the estate of Charlotte Douglas, filed a complaint against cigarette companies and industry organizations for damages on claims based on Charlotte's smoking-related death. After a jury trial, Plaintiff was awarded $2.5 million in damages. At issue on appeal was whether the trial court erred in the application of the Phase I findings in the class action case Engle v. Liggett Group, Inc. Charlotte was a member of the Engle class. The court of appeal affirmed, concluding that Plaintiff did not prove legal causation on his negligence theory but did prove legal causation on his strict liability claim. Although the court of appeal rejected Defendants' argument that applying res judicata to the findings violated their due process rights, it certified the due process question to the Supreme Court. The Court approved of the court of appeal's decision affirming the general verdict for Plaintiff based on strict liability but disapproved the court's rejection of negligence as a basis for the general verdict because the court's analysis required causation instructions and findings beyond those required by Engle. In addition, the Court answered that accepting as res judicata the eight Phase I findings approved in Engle did not violate Defendants' due process rights. View "Philip Morris USA Inc. v. Douglas" on Justia Law

The Florida Judicial Qualifications Commission (JQC) instigated formal proceedings against circuit court Judge R. Timothy Shea for the judge's rude and intemperate behavior. After the Supreme Court disapproved the proposed sanction, the JQC withdrew its findings and recommendation of discipline and subsequently filed amended formal charges against Judge Shea. Based on facts set out in a second stipulation, the JQC filed a second findings and recommendation of discipline, determining that Judge Shea engaged in inappropriate behavior that was unbecoming a member of the judiciary. The JQC recommended that Judge Shea receive a public reprimand with the additional requirement that the judge send letters of apology to those individuals identified in the notice of amended formal charges and continue to obtain mental health treatment as recommended by his doctor and family therapist. The Supreme Court approved the JQC's findings and recommended discipline based on the severity of the judge's misconduct and the mitigating factors in his case. View "In re Shea" on Justia Law