Justia Florida Supreme Court Opinion Summaries

Plaintiff, a resident of Arizona, sued Defendant, a foreign corporation that operates in Florida, after he contracted to buy an aircraft from Defendant but Defendant failed to deliver the aircraft. The U.S. district court applied Florida with respect to some of Plaintiff's claims and applied Arizona law to the remainder of the claims. The court also denied Defendant's motion for attorney's fees under the Florida Deceptive and Unfair Trade Practices Act (FDUTPA). On appeal, the Eleventh Circuit certified several questions to the Florida Supreme Court. The Court answered (1) because Plaintiff invoked FDUTPA by filing an action asserting a claim seeking recovery under FDUTPA in which Defendant ultimately prevailed, Defendant was entitled to attorney's fees under FDUPTA; (2) Defendant was entitled to fees for only the period of litigation until the federal district court held that FDUPTA did not apply to Plaintiff's claim; (3) Florida's offer of judgment statute does not apply to cases that seek both equitable relief and damages and in which Defendant has served an offer of judgment that seeks release of all claims; and (4) even if Florida's offer of judgment statute applied in this case, Defendant would not be entitled to attorney's fees under that section. View "Diamond Aircraft Indus., Inc. v. Horowitch" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended a death sentence. Following a Spencer hearing, the trial court sentenced Defendant to death upon determining that the State had proven beyond a reasonable doubt the existence of several statutory aggravators. The Supreme Court affirmed the conviction and sentence, holding (1) the evidence presented at trial was sufficient to support the first-degree murder conviction; (2) under the totality of the circumstances, the death sentence in this case was proportionate; (3) Florida's protocol for execution by lethal injection is constitutional; and (4) Florida's capital sentencing process is constitutional. View "Kocaker v. State" on Justia Law

Plaintiff filed a medical malpractice action against a dentist (Dentist) and his dental practice, alleging that Dentist's failure to diagnose and treat his dental conditions resulted in a bone infection and a worsening of his dental problems, which caused severe and permanent physical and emotional damage. In preparation for trial, there was an ex parte predeposition conference conducted between Plaintiff's nonparty treating physician and counsel provided by Defendant's insurance company. Plaintiff contended that the ex parte meeting violated the State's physician-patient confidentiality statute as delineated in Fla. Stat. 456.057(8). The Supreme Court held that section 456.057 prohibits such meetings and quashed the decision of the Fourth District holding otherwise. In particular, the Court held that an ex parte meeting such as the one attempted here is prohibited irrespective of whether the attorney and physician claim they will discuss only non-privileged matters. View "Hasan v. Garvar" on Justia Law

Defendant was originally convicted in 1981 for murder and sentenced to death. After a series of appeals and postconviction motions, Defendant filed a successive motion to vacate his sentence. Specifically, Defendant asserted that he was mentally retarded pursuant to Atkins v. Virginia. The trial court held an evidentiary hearing on Defendant's motion in 2009. The court denied relief, determining that Defendant could not meet the first prong of the mental retardation standard to establish his mental retardation. The Supreme Court affirmed, holding that there was competent, substantial evidence to support the court's finding that Defendant was not mentally retarded. View "Hall v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder, one count of burglary with assault or battery while armed, and one count of criminal mischief. The trial court imposed death sentences for both murders. The trial court subsequently denied Defendant's motion for postconviction relief. Defendant appealed the trial court's denial of his motion and petitioned the Supreme Court for a writ of habeas corpus. The Court affirmed the denial of Defendant's postconviction motion and denied his habeas petition, holding, among other things, that (1) Defendant's trial counsel did not provide ineffective assistance during the guilt phase or the penalty phase; (2) the State did not violate Brady v. Maryland by withholding evidence; (3) trial counsel was not operating under an actual conflict of interest due to counsel's workload; (4) the trial court did not err in denying several of Defendant's requests for additional public records; and (5) Defendant was not entitled to relief on any of the claims he raised in his habeas petition. View "Dennis v. State" on Justia Law

Defendants pled nolo contendere to charges of violating the sound standards of Fla. Stat. 316.3045(1)(a), reserving the right to appeal the constitutionality of the statute. Defendants subsequently appealed, arguing that the statute's "plainly audible" standard was constitutionally vague, overbroad, invited arbitrary enforcement, and impinged on their free speech rights. Bound by the Second District's decision in Easy Way of Lee County v. Lee County, the circuit court reversed. On appeal, the Second District denied the State's petition for certiorari relief, holding (1) the "plainly audible" standard of noise ordinance was unconstitutional, and (2) section 316.3045(3) was an unconstitutional content-based restriction because it contained an exemption for vehicles used for business and political purposes that use sound-making devices in the normal course of operations. The Supreme Court (1) affirmed the Second District's declaration that section 316.3045(1)(a) was invalid because it was an unreasonable restriction on the freedom of expression; (2) held that the statute was unconstitutionally overbroad, but not unconstitutionally vague; and (3) found that section 316.3045(3) was not severable from the remainder of the statute. View "State v. Catalano" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, kidnapping, and robbery. The trial court sentenced Defendant to death for the first-degree murder. The Supreme Court affirmed the convictions and sentences, holding, among other things, that the trial court did not err by (1) striking jurors based on hardship; (2) prohibiting Defendant from presenting testimony relating to the victim's inclination to pick up men at a park and bring them home; (3) limiting cross-examination of a jailhouse informant; (4) giving a voluntary intoxication instruction; (5) denying Defendant's motion to suppress his confession to the police and items found pursuant to the search of his duffel bag; (6) admitting autopsy photographs into evidence; and (7) denying Defendant's motion for acquittal. In addition, the Court found there was sufficient evidence to sustain Defendant's conviction for first-dgree murder, the death sentence in this case was proportionate, and Florida's death penalty sentence was constitutional. View "Patrick v. State" on Justia Law

A jury found Defendant guilty of nine counts of first-degree murder. The trial court imposed a death sentence for each of the first-degree murder counts. The convictions and death sentences were affirmed on appeal, and Defendant's subsequent motion for postconviction relief and petition for writ of habeas corpus were denied. The Governor signed a death warrant for Defendant, and the execution was set for December 11, 2012. Defendant filed a successive motion for postconviction relief, which the circuit court denied. The Supreme Court affirmed, holding that the circuit court did not err in (1) denying relief on Defendant's constitutional challenge to Florida's lethal injection protocol; (2) denying Defendant's public records requests; (3) denying Defendant's claim that he was incompetent to stand trial as procedurally barred; (4) denying relief on Defendant's claim that he was denied a full and fair clemency proceeding; and (5) denying Defendant's claim that executing him after the twenty-four years he spent on death row constituted cruel and unusual punishment. View "Pardo v. State" on Justia Law

Defendant pled guilty to twelve criminal counts related to the attempted kidnapping and shooting of two women who were sitting in a car. One of the women died as a result of the injuries she sustained when Defendant attempted to escape and crashed the car into a tree. On direct appeal, the Supreme Court affirmed Defendant's convictions but vacated his death sentence and remanded for a new penalty phase in light of the trial court's failure to consider all of the available mitigation. At the conclusion of the new penalty phase, Defendant was once against sentenced to death. The Supreme Court affirmed. Defendant subsequently filed a motion for postconviction relief, raising eleven allegations of error. The trial court denied all claims for relief. In addition to his appeal, Defendant also filed a petition for writ of habeas corpus, raising four claims. The Supreme Court (1) affirmed the trial court's denial of postconviction relief; and (2) denied Defendant's petition for habeas corpus relief. View "Farr v. State" on Justia Law

Petitioner, who was born in Nicaragua and entered the United States as a child, pleaded guilty to sale of a controlled substance, a second degree felony, in 2001. Following the U.S. Supreme Court's decision in Padilla v. Kentucky in 2010, Petitioner filed a postconviction motion alleging that his counsel failed to advise him that deportation was mandatory for the offense to which he pled guilty and that he would not have pled guilty if he had known that it would mandate his deportation without recourse. The circuit court denied Petitioner's motion on the basis that the immigration consequences warning included in the plea colloquy pursuant to Fla. R. Crim. P. 3.172(c)(8) precluded Petitioner from establishing the requisite prejudice under Strickland v. Washington. The Third District Court of Appeal upheld the denial of Petitioner's postconviction motion and then certified questions of law to the Florida Supreme Court. The Supreme Court answered (1) the immigration warning in Rule 3.172(c)(8) does not bar immigration-based ineffective assistance of counsel claims based on Padilla; and (2) however, the ruling in Padilla does not apply retroactively. Therefore, the Court approved of the Third District's decision upholding the denial of Petitioner's postconviction motion. View "Hernandez v. State" on Justia Law