Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's sentences of death imposed in connection with his conviction for two counts of first-degree murder, holding that Defendant was not entitled to relief on his claims of error.After he was originally convicted and sentenced Defendant received a new penalty phase in light of Hurst v. State, 202 So. 3d 40 (Fla. 2016). Thereafter, Defendant was resentenced to death for both murders. The Supreme Court affirmed Defendant's sentences of death, holding (1) Defendant's jury unanimously found that each of five aggravating factors was proven beyond a reasonable doubt; (2) there was no error in allowing the State to amend its notice of aggravating factors; (3) the trial court did not err in permitting the introduction of victim impact evidence; and (4) Defendant was not entitled to relief on his remaining claims of error. View "McKenzie v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court summarily denying Appellant's sixth successive motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, holding that the trial court did not err in summarily denying Appellant's postconviction motion.Appellant was convicted of first-degree murder, sexual battery, and burglary. The trial judge sentenced Appellant to death. In his sixth successive postconviction motion Appellant asserted two claims, including a claim under Brady v. Maryland, 373 U.S. 83 (1963). The trial court rejected both claims. The Supreme Court affirmed, holding that the trial court did not err in summarily denying Appellant's sixth postconviction motion. View "Booker v. State" on Justia Law

The Supreme Court held that Plaintiff's unjust enrichment claim failed because he received adequate consideration in exchange for the challenged fee when he took advantage of the privilege of using his credit card to pay the penalty.Plaintiff filed a putative class action arguing that a convenience fee that Plaintiff paid in connection with a penalty he paid with his credit card to the City of North Miami Beach. Plaintiff argued that the convenience fee was statutorily prohibited and that American Traffic Solutions, Inc. (ATS), with whom the City had contracted to issue and mail citations and process violators' payments of the civil penalties imposed, was unjustly enriched by retaining the fee. The trial court dismissed the complaint for failure to state a claim. The court of appeals certified a question to the Supreme Court, which answered that Plaintiff's unjust enrichment claim failed because he had not alleged a benefit conferred and accepted which would be unjust for ATS to retain. View "Pincus v. American Traffic Solutions, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and his sentence of death, holding that there was no error in the proceedings below.Defendant entered a no contest plea to first-degree murder, attempted murder of a correctional officer with a deadly weapon, and other crimes. The trial court sentenced Defendant to death. The Supreme Court affirmed the convictions and sentences, holding (1) the trial court did not abuse its discretion by not employing all of the mitigation-investigation procedures required in Muhammad v. State, 782 So. 2d 343 (Fla. 2001), because Muhammad's investigative procedures did not apply; (2) Defendant's second assignment of error was without merit; and (3) Defendant voluntarily and knowingly entered his no contest plea. View "Bell v. State" on Justia Law

The Supreme Court held that a deed covenant requiring the arbitration of any dispute arising from a construction defect runs with the land such that it is binding upon a subsequent purchaser of the real estate who was not a party to the deed.The home in this case was constructed and sold by U.S. Home Corp. to the original purchasers. The original deed contained an arbitration provision and several covenants, conditions and restrictions concerning the home that bound both the original purchasers and subsequent purchasers. The original purchasers later sold the home to Plaintiffs, who brought suit against U.S. Home pursuant to Fla. Stat. 553.84. U.S. Home filed a motion to stay and compel arbitration, which the circuit court granted. The Second District Court of Appeal affirmed, concluding that a valid arbitration agreement existed and that it was a covenant running with the land. The Supreme Court approved the decision below, holding that Plaintiffs were bound by the arbitration provision. View "Hayslip v. U.S. Home Corp." on Justia Law

In this dispute over the power to make changes to a county sheriff's budget the Supreme Court held that the Sheriff of Alachua County is not permitted under Florida Statutes chapters 30 and 129 to make object-level transfers without the approval of the Alachua County Board of County Commissioners.At issue was the Sheriff's authority to transfer money within the Sheriff's budget at a level of detail called the "object" level under chapters 30 and 129. The County brought this action seeking a declaratory judgment that the Sheriff had no authority to move approximately $840,000 between two objects in the budget without approval from the County. The court of appeal affirmed the trial court's conclusion that the Sheriff had the authority to make transfers at the object level without County approval. The Supreme Court quashed the decision below, holding that when seeking to transfer money between objects, the Sheriff must follow the budgetary amendment process set forth in chapter 129 and that the Sheriff failed to do so in this case. View "Alachua County v. Watson" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief.Appellant was convicted of first-degree murder. In a seven-to-five vote recommendation the jury sentenced Appellant to death, and the death sentence became final in 1989. In his postconviction motion, Appellant argued that he was entitled to retroactive application of the Supreme Court's decision in State v. Poole, 297 So. 3d 487 (Fla. 2020), which receded from Hurst v. State, 202 So. 3d 40 (Fla. 2016) except as to the requirement that a jury must unanimously find the existence of a statutory aggravating circumstance beyond a reasonable doubt. The Supreme Court denied relief, holding that Poole did not retroactively apply to Appellant. View "Jackson v. State" on Justia Law

The Supreme Court reversed Defendant's convictions for first-degree murder and sentences of death, holding that the introduction of the testimony of Defendant's mother constituted harmful error.During Defendant's trial, Defendant's mother, Jeanne Avsenew, testified regarding multiple incriminating statements made and actions taken by Defendant shortly after the murders. At issue was whether the perpetuated testimony testimony of Jeanne, which was given despite her inability to see Defendant during her testimony, violated Fla. R. Crim. P. 3.190(i)(3), which requires that the defendant be in the witness's presence during testimony. The Supreme Court reversed, holding (1) the failure to ensure that Defendant was kept in the presence of his mother during her testimony constituted a clear violation of Rule 3.190(i)(3); and (2) the error was not harmless. View "Avsenew v. State" on Justia Law

The Supreme Court vacated Defendant's convictions for first-degree murder and remanded this case to the trial court for a new trial, holding that Defendant was entitled to postconviction relief as to the guilt phase of his trial.A jury found Defendant guilty of two murders, and the trial court ultimately imposed a sentence of death for each murder. The Supreme Court affirmed on direct appeal. Defendant subsequently filed a motion for postconviction relief, raising several Brady claims as to the guilt phase of his trial. The postconviction court denied relief. The Supreme Court reversed the denial of postconviction relief as to the guilt phase and vacated Defendant's murder convictions, holding (1) the State committed a Brady violation by failing to disclose that one of the witnesses was a confidential informant for the State; and (2) the Brady violation undermined confidence in the outcome of the trial. View "Simpson v. State" on Justia Law

In this considering the provisions of a personal injury protection (PIP) insurance policy permit permitting the insurer to limit reimbursement payments in accordance with a statutory schedule of maximum charges the Supreme Court held that the PIP policy in this case was effective to authorize the use of the schedule of maximum charges under the pertinent provisions of Fla. Stat. 627.736(5).The certified question in this case related to the Second District Court of Appeal's holding that State Farm's policy provisions permitted State Farm to use the schedule of maximum charges even though the policy also referred to the use of other statutory factors for determining reasonable charges. The Supreme Court affirmed, holding that the PIP policy issued by State Farm was effective to authorize the use of the schedule of maximum charges under the relevant provisions of Fla. Stat. 627.736(5). View "MRI Associates of Tampa, Inc. v. State Farm Mutual Automobile Insurance Co." on Justia Law