Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's second successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851, holding that there was no error.The State charged Appellant with first-degree murder. Following a second trial, a jury found Defendant guilty and recommended a sentence of death. The Supreme Court reversed due to a jury selection error. On remand, a jury again found Defendant guilty. The trial court sentenced him to death. The Supreme Court affirmed, holding that the circuit court did not err in denying Appellant's newly discovered evidence and Brady claims. View "Valentine v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court summarily denying Defendant's seventh motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the trial court did not err in summarily denying relief.The State charged Defendant with first-degree murder and other crimes. Defendant pled guilty to each of the charged offenses, and the trial court sentenced him to death. After the death sentence became final, Defendant sought postconviction relief in state and federal courts, without success. Defendant later brought the postconviction motion at issue on appeal arguing that the trial court's failure to conduct a hearing pursuant to Hall v. Florida, 572 U.S. 701 (2014), constituted reversible error. The Supreme Court affirmed, holding that Defendant could not succeed on his Hall-based intellectual disability claim, and therefore, the trial court did not err in summarily denying that claim. View "Thompson v. State" on Justia Law

The Supreme Court quashed the decision of the Second District Court of Appeal reversing the circuit court's grant of Airbnb, Inc.'s motion to compel arbitration, holding that the circuit court did not err in compelling arbitration.Plaintiffs brought this complaint against Airbnb, alleging constructive intrusion and loss of consortium. After a hearing, the circuit court granted Airbnb's motion to compel arbitration and stayed the underlying lawsuit pending arbitration, finding that the parties entered into an express agreement that incorporated the the American Arbitration Association (AAA) rules, requiring Airbnb to submit the issue of arbitrability to the arbitrator. The Second District Court reversed, concluding that the arbitration provision and the AAA rule it referenced did not amount to "clear and unmistakable" evidence that the parties agreed to arbitrate arbitrability. The Supreme Court reversed, holding that Airbnb's terms of service that incorporate by reference rules that expressly delegate arbitrability determinations to an arbitrator constitute clear and unmistakable evidence of the parties' intent to authorize an arbitrator, rather than a court, to resolve questions of arbitrability. View "Airbnb, Inc. v. Doe" on Justia Law

The Supreme Court quashed the decision of the Third District Court of Appeal concluding that the circuit court had personal jurisdiction over Tribeca Asset Management, Inc., holding that the parties' agreement did not provide for arbitration in Florida.Tribeca and Ancla International, S.A. entered into a confidentiality agreement. Ancla later filed a petition to compel arbitration. The circuit court dismissed the petition for lack of personal jurisdiction, concluding that a provision in the parties' agreement did not contain a forum selection clause and merely contained a choice of law provision. The Third District reversed, concluding that the provision contained a forum selection clause. The Supreme Court reversed, holding that the agreement did not provide for arbitration in Florida. View "Tribeca Asset Management, Inc. v. Ancla International, S.A." on Justia Law

The Supreme Court sanctioned Petitioner, an inmate in state custody, holding that Petitioner failed to show cause why he should not be barred.Petitioner was convicted of first-degree murder and robbery with a gun or deadly weapon. Since 2009, Petitioner demonstrated a pattern of vexatious filing of meritless pro se requests for relief in this Court related to his case, including the pro se petition in the instant case, which the Supreme Court treated as a petition for writ of habeas corpus. The Supreme Court dismissed the petition and directed the clerk of court to reject any future pleadings or other requests for relief unless such filings are signed by a member in good standing of The Florida Bar. View "Rivera v. Dixon" on Justia Law

The Supreme Court held that conviction on multiple counts under Fla. Stat. 316.062(2) stemming from a single crash involving multiple victims does not expose a defendant to multiple punishments for one offense in violation of constitutional double jeopardy protections.Under section 316.027, when a car crash results in the injury or death of "a person," the driver of a vehicle involved in the crash must stop and remain at the scene until fulfilling the requirements of Fla. Stat. 316.062, which requires the driver to provide identifying information to any injured person and the police and to render reasonable assistance to any injured person. Defendant was convicted of four violations of section 316.027(2), one violation for each victim of one crash. The court of appeal vacated two of Defendant's three convictions as violating double jeopardy principles. The Supreme Court quashed the decision below, holding (1) section 316.027(2) contemplates a per-crash-victim unit of prosecution rather than on a per-crash basis; and (2) therefore, Defendant's separate convictions for each crash victim were not multiple punishments for the same offense. View "State v. Johnson" on Justia Law

The Supreme Court approved the holding of the court of appeal that Fla. Const. art. I, 14 does not prohibit the trial court the discretion at first appearance, upon a finding of probable cause that the defendant committed a crime punishable by capital punishment or life imprisonment, to defer ruling on bail and to detain the defendant for a reasonable time to conduct a "full" Arthur bond hearing, holding that there was no error.Defendant was arraigned on one count of robbery using a firearm or deadly weapon. After a hearing held pursuant to State v. Arthur, 390 So. 2d 717 (Fla. 1980) the trial court concluded that the evidence was sufficient to convict Defendant of unarmed robbery and granted him pretrial release and bail in the amount of $25,000. On appeal, Defendant argued that the first sentence of article 1, section 14 creates a two-step procedure. The court of appeals rejected this argument. The Supreme Court affirmed, holding that article I, section 14 does not prohibit a trial court from detaining a defendant beyond first appearance without setting release unless the court has made a preliminary finding that the proof of guilt is evident or the presumption is great. View "Thourtman v. Junior" on Justia Law

The Supreme Court held that an "Engle progeny" plaintiff must prove reliance on a statement that was made by an Engle defendant for a concealment claim or co-conspirator for a conspiracy claim and that concealed or omitted material information about the addictiveness or health effects of smoking cigarettes.Plaintiff, on behalf of a deceased smoker, brought this wrongful death lawsuit. The jury found that the decedent was a member of the Engle class then found in Plaintiff's favor on her claims for strict liability, negligence, and concealment conspiracy. The court of appeal vacated the judgment, concluding that the trial court's refusal to give Defendant's requested special instruction on reliance was both erroneous and prejudicial. The Supreme Court approved the court of appeal's decision, holding that Defendant's requested jury instruction on concealment conspiracy was correct, and the trial court's instruction was both erroneous and prejudicial. View "Prentice v. R.J. Reynolds Tobacco Co." on Justia Law

The Supreme Court affirmed the order of the circuit court denying Billy Sheppard Jr.'s motion to vacate his conviction of first-degree murder and denied Sheppard's petition for a writ of habeas corpus, holding that the circuit court properly denied postconviction relief for all guilt claims and that Sheppard failed to establish that he was entitled to habeas corpus relief.Sheppard was convicted of first-degree murder and sentenced to death. Sheppard later filed a motion to vacate his conviction and sentence under Fla. R. Crim. P. 3.851. The circuit court granted a new penalty phase but denied Sheppard's claims as to the guilt phase of his trial. Sheppard appealed, raising claims relevant to the guilt phase, and filed a petition for writ of habeas corpus raising two claims of ineffective assistance of counsel. The Supreme Court affirmed the circuit court's order and denied Sheppard's petition for writ of habeas corpus, holding that Sheppard was not entitled to relief on any of his claims. View "Sheppard v. State" on Justia Law

The Supreme Court held that Fla. Stat. 120.68(3), which entitles a party to a presumptive stay upon the appeal of an agency decision that "has the effect of suspending or revoking a license," does not apply to an agency decision to administratively withdraw an incomplete renewal license application.When Ybor Medical Injury and Accident Clinic, Inc. (the clinic), applied to the Agency for Health Care Administration (AHCA) to renew its expiring license the AHCA invited the clinic to supplement its application, which was incomplete. After the clinic failed to do so, AHCA administratively withdrew the incomplete renewal license application from further consideration. The AHCA appealed and sought a presumptive stay under section 120.68(3). The court of appeals granted the presumptive stay. The Supreme Court quashed the decision below, holding that the appeal of an agency’s withdrawal decision does not trigger the statute’s presumptive stay provision. View "Agency for Health Care Administration v. Ybor Medical Injury & Accident Clinic, Inc." on Justia Law