Justia Florida Supreme Court Opinion Summaries

Defendant was convicted of first degree murder, both premeditated and felony murder, as well as other felony counts, and sentenced to death. On instant appeal, defendant raised claims of ineffective assistance of trial counsel pertaining to both the guilt and penalty phase of trial and raised a claim arising after the court's remand to the circuit court, challenging the fairness of the postconviction evidentiary hearing based upon the denial of his motion to disqualify the circuit judge and the exclusion of certain testimony and evidence at the hearing. The court discussed each claim and held that the circuit court's order denying defendant's Florida Rule of Criminal Procedure 3.851 amended motion was affirmed. View "Mendoza v. State" on Justia Law

Defendant appealed the denial of his amended and supplemental motions for postconviction relief and petitioned for writ of habeas corpus where he was convicted of first degree murders and sentenced to death for the commission of a triple homicide. Defendant raised numerous claims before the court on appeal but focused primarily on two of those claims: whether the state presented expert testimony on comparative bullet lead analysis (CBLA), which evidence had now established was no longer a reliable science, and whether newly discovered evidence showed that a critical state witness testified untruthfully. The court held that the 2008 letter at issue clearly qualified as newly discovered evidence; thus, the postconviction court erred in finding that the claim was procedurally barred and that the letter did not constitute newly discovered evidence. Regardless of these errors, the court affirmed the postconviction court's denial of relief because defendant could not demonstrate that consideration of the letter would probably produce an acquittal on retrial under the newly discovered evidence standard. The court also held that, as to the Brady v. Maryland and Giglio v. United States claims, there was no basis for concluding that the state withheld favorable evidence under Brady or knowingly presented evidence at the original trial under Giglio. After the FBI discovered the errors in the original CBLA evidence introduced at trial, defendant was made aware of these errors by letter. The court rejected defendant's ineffectiveness claim because the record showed that trial counsel retained an independent expert to evaluate the FBI's CBLA and the expert provided counsel with no basis to challenge that analysis. Therefore, the court affirmed the postconviction court's denial of relief and also denied defendant's habeas petition. View "Wyatt v. State; Wyatt v. Buss" on Justia Law

Defendant appealed from a judgment of conviction of first degree murder and a sentence of death. Defendant was also convicted of home invasion robbery with a firearm, kidnapping, and aggravated fleeing and eluding a law enforcement officer. Defendant raised various issues on appeal regarding his post-arrest interrogation; letter of apology; victim impact statements; how the murder was committed in a cold, calculated, and premeditated manner; how the murder was especially heinous, atrocious, or cruel; proportionality of the sentence; Ring v. Arizona; and sufficiency of the evidence. The court addressed each of defendant's claims and held that the convictions and sentences were affirmed. View "Baker v. State" on Justia Law

Defendant was convicted of four counts of first-degree murder and was sentenced to death for each of the murders. On direct appeal, defendant raised eleven claims regarding his competency at trial, his self-representation, limitations on his narrative testimony, the prosecutor's closing argument, evidence of collateral acts, removals from the courtroom, penalty phase jury instructions, his limitation on mitigating evidence, sufficiency of the evidence, and proportionality review of the sentence. The court addressed each claim and concluded that defendant's convictions and sentences of death were affirmed. View "McCray, II v. State" on Justia Law

Defendant was arrested and charged with possession of cannabis in an amount greater than 25 pounds, but less than 2000 pounds. Defendant filed a motion to suppress all evidence seized based on the May 16, 2007 warrant. At issue was whether a law enforcement officer's failure to sign an affidavit in support of a search warrant invalidated the warrant. The court held that the failure of the law enforcement officer to sign the affidavit did not render the search warrant invalid because, based upon all the circumstances surrounding the issuance of the warrant, the error constituted a technical flaw. Accordingly, the trial court erred by suppressing the evidence exclusively on that basis. View "Moreno-Gonzalez v. State" on Justia Law

Petitioner, a juvenile, was convicted for trespassing upon the grounds of a school facility in violation of section 810.097(2), Florida Statutes. At issue was whether the prosecution must prove the identity of the individual who warned defendant to leave the grounds of the school, and that individual's authority to restrict access to the property, as essential elements of the trespass offense. The court held that the individual's identity and authority were essential elements of the offense and quashed the decision of the Third District. The court also held that, because in this case the state failed to present any evidence demonstrating that the petitioner was warned to leave by the school's principal or a designee of the principal, petitioner's conviction must be vacated. View "D.J. v. State" on Justia Law

This case stemmed from a warrantless "sniff test" by a drug detection dog at defendant's home and the subsequent discovery of live marijuana plants inside. At issue was whether the "sniff test" was a search under the Fourth Amendment and if so, whether the evidentiary showing of wrongdoing that the government must make prior to conducting such a search was probable cause or reasonable suspicion. The court held that in the present case, the "sniff test" was a substantial government intrusion into the sanctity of the home and constituted a search within the meaning of the Fourth Amendment. The court also held that probable cause, not reasonable suspicion, was the proper evidentiary showing of wrongdoing that the government must make prior to conducting the "sniff test." Accordingly, the court quashed the district court's decision. View "Jardines v. State" on Justia Law

Defendant was convicted of robbery with a deadly weapon and first degree murder. Defendant appealed his conviction and sentence of death under Florida Rule of Criminal Procedure 3.850. The court affirmed and held that the post conviction court did not err when it denied postconviction relief because trial counsel was not ineffective and the life sentence of the co-defendant did not constitute newly discovered evidence. View "Nelson v. State" on Justia Law

This appeal arose from a motion for class certification filed in the trial court by petitioner where petitioner claimed that respondent violated sections 627.840(3)(b) and 627.835, Florida Statutes, by knowingly overcharging him an additional service charge of $20 twice in a twelve month period in two premium finance agreements which he entered into with respondent. At issue was whether the putative class members satisfied the requirements of commonality and predominance needed for class certification under Florida Rule of Civil Procedure 1.220. The court held that the Third District's decision was incorrect because it afforded no deference to the trial court's actual factual findings and conducted a de novo review which constituted error where the proper appellate standard of review for a grant of class certification was abuse of discretion. The court also held that the Third District incorrectly addressed whether petition satisfied section 627.835's "knowingly" requirement and incorrectly held that petitioner and the putative class members failed to satisfy rule 1.220's commonality and predominance requirements. Therefore, the court held that the Third District created conflict with Olen Properties Corp. v. Moss and Smith v. Glen Cove Apartments Condominiums Master Ass'n. Accordingly, the court quashed the Third District's judgment. View "Sosa, etc. v. Safeway Premium Fin. Co., etc." on Justia Law

Parents of a minor child sued defendants for the permanent and substantial brain injury of their child. The issue in these consolidated cases was whether the parents were precluded from suing in a court of law for damages sustained by alleged malpractice and instead were required to pursue limited compensation in an administrative forum provided by the statute under the Florida Birth-Related Neurological Injury Compensation Plan (NICA plan). The court held that because the First District failed to read the phrase "immediate postdelivery period" as modifying "resuscitation," the First District expanded the NICA plan to cover infants beyond the limit contemplated by the express language of the statute. The court also held that the First District incorrectly held that under section 766.309(1)(a), Florida Statutes, the rebuttable presumption of coverage under the NICA plan applied to benefit defendants, even though plaintiffs were not making a claim for compensation under the NICA plan. Accordingly, in reviewing the facts under the correct interpretation of the statute, the court held that the ALJ's finding that the child did not sustain a "birth-related neurological injury" under the NICA plan was supported by competent, substantial evidence. View "Bennett, et al. v. St. Vincent's Med. Center, Inc., et al.; FL Birth-Related Neurological Injury Compensation Assoc. v. St. Vincent's Med. Center, Inc., et al." on Justia Law