Justia Florida Supreme Court Opinion Summaries

The Supreme Court quashed the decision of the Third District Court of Appeal affirming Defendant's convictions of driving under the influence (DUI) causing damage to property or person and DUI causing serious bodily injury, holding that Defendant's dual convictions violated double jeopardy.On appeal, Defendant argued that his dual convictions arising from a single episode violated double jeopardy. The Third District affirmed, holding that principles of double jeopardy did not prohibit dual convictions and sentences for DUI property damages/bodily injury and DUI serious bodily injury arising from the commission of a single act. The Supreme Court reversed, holding (1) the criminal offenses of DUI causing damage to property or person and DUI causing bodily injury are degree variants of the same offense under Fla. Stat. 775.021(4)(b)2; and (2) Defendant's dual convictions for both offenses as to the same victim arising from a single episode violated the prohibition against double jeopardy. View "Velazco v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying the guilt-phase claims Kim Jackson raised in his motion for postconviction relief filed under Fla. R. Crim. P. 3.851 and denied Jackson's petition for a writ of habeas corpus, holding that Jackson was not entitled to relief.After a jury trial, Jackson was found guilty of first-degree murder and sentenced to death. The Supreme Court affirmed. Jackson subsequently filed a postcondition motion raising more than twenty claims for relief. The circuit court vacated Jackson's death sentence under Hurst v. State, 202 So. 3d 40 (Fla. 2016), and otherwise affirmed. The Supreme Court affirmed and denied habeas corpus relief, holding (1) a due process claim for preindictment delay requires a showing of substantial prejudice to the defendant and bad faith on the part of the State; (2) as to two of Jackson's claims of ineffective assistance of counsel this Court assumed deficient performance but found no prejudice; and (3) Jackson was not entitled to a writ of habeas corpus. View "Jackson v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Defendant's second successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851, holding that there was no error.After a jury trial, Defendant was found guilty of four counts of first-degree murder. After a bench penalty phase, the trial court sentenced Defendant to death. At issue was Defendant's second successive postconviction motion asserting four claims for relief. The circuit court summarily denied all of Defendant's claims. The Supreme Court affirmed, holding that the circuit court did not err in summarily denying Defendant's second successive motion for postconviction relief. View "Hutchinson v. State" on Justia Law

The Supreme Court held that, subject to the procedural constraints of Fla. R. Crim. P. 3.800(b), a trial court has the inherent authority to sua sponte correct sentencing documents that overreport the amount of jail time served by a defendant previous to sentencing or the amount of jail time and prison time served by a defendant prior to sentencing.Rather than defer to the Department of Correction the calculation of Defendant's prison credit, the clerk erroneously calculated the totals of jail and prison credit, resulting in sentencing documents that not only overreported the amount of Defendant's credit for time served but did not distinguish between jail and prison credit. The Supreme Court held that the sua sponte corrections to Defendant's sentencing documents, which the trial court made after Defendant's appeal was over, were untimely and could not stand. View "Spear v. State" on Justia Law

Ritchie sexually battered and strangled to death nine-year-old F.W., who had been left in Ritchie’s care by a friend, then dumped the child’s body in the water off of the Courtney Campbell Causeway and fabricated a story about her disappearance. The Florida Supreme Court affirmed his conviction for first-degree murder and his sentence of death. The court rejected claims that the cumulative impact of improper comments by the prosecutor during the penalty phase closing argument deprived Ritchie of a fair penalty phase; Florida law regarding the presentation of victim impact evidence is unconstitutional on its face and as applied in his case; the trial court erred in ordering audio redactions to a mitigation video submitted by Ritchie and by allowing the state to present improper rebuttal evidence to the video; and the cumulative prejudicial effect of the trial errors alleged in issues one through three deprived him of a fair penalty phase. Ritchie’s case is not one where the “jury recommendation of death could not have been obtained without the assistance of” the errors. The aggravators “greatly outweighed” the scant mitigation. The court acknowledged that the state easily could have avoided the errors that occurred and that similar errors, particularly if preserved, might be outcome-determinative in a closer case. View "Ritchie v. State of Florida" on Justia Law

The Supreme Court held that a sentencing court may rely on a defendant's lack of remorse after the defendant has given a post-Miranda, sworn confession to the crime and has obviously lied under oath at trial about his guilt.Defendant gave a sworn confession to the crimes of which he was convicted but retracted the confession during his trial testimony. The district court felt "constrained" to reverse Defendant's sentence on the grounds that the trial court improperly relied on Defendant's subsequent claim of innocence in imposing the sentence. The Supreme Court quashed the decision of the First District Court of Appeal, which vacated Defendant's aggregate 300-year sentence and remanded for resentencing, holding that the court was under no obligation to ignore the "freely offered statements" that Defendant made during trial rather than at allocution. View "State v. Burns" on Justia Law

The Supreme Court approved the ruling of the Fifth District Court of Appeal that a trial court may order a defendant over whom it has in personam jurisdiction to act on foreign property pursuant to Fla. Stat. 56.29(6), holding that a trial court has the authority to order a defendant over whom it has in personam jurisdiction to act on foreign property.The district court concluded that section 56.29(6) plainly authorizes a trial court to order a debtor, over whom the court has in personam jurisdiction, to act on assets located outside of the court's territorial jurisdiction. The Supreme Court approved the district court's ruling, holding that the trial court in this case undisputedly had in personam jurisdiction over the debtor and therefore compel him to act on his foreign assets under section 56.29(6). View "Shim v. Buechel" on Justia Law

The Supreme Court approved the decision of the Second District Court of Appeal in this workers' compensation dispute, holding that Fla. Stat. 440.13(11)(c), a section of the Workers' Compensation (WCL), does not preclude circuit court jurisdiction over claims brought under Fla. Stat. 559.77(1), a section of the Florida Consumer Collection Practices Act (FCCPA).In the proceedings below, the Second District concluded that a provision of the WCL vesting the Department of Financial Services (DFS) with exclusive jurisdiction to decide matters concerning workers' compensation reimbursement was inapplicable as a bar to suit by an injured worker against a healthcare provider for prohibited debt collection practices. The Supreme Court approved the result, holding that the matter at issue in this case under the FCCPA was not a matter concerning reimbursement subject to the exclusive jurisdiction of DFS. View "Laboratory Corp. of America v. Davis" on Justia Law

The Supreme Court approved findings of misconduct made by the Hearing Panel of the Florida Judicial Qualifications Commission (Hearing Panel) concerning Circuit Judge Barbara Kaye Hobbs, found Judge Hobbs guilty to as to one additional violation, and imposed the Hearing Panel's recommended discipline, in addition to ordering Judge Hobbs to pay a fine.The Hearing Panel found Judge Hobbs guilty of the three charges for which she had conceded guilt and one additional charge. The Panel recommended that Judge Hobbs be publicly reprimanded, suspended from office without pay for sixty days, and compelled to attend an employee management program. The Supreme Court accepted the Hearing Panel's findings as to all charges and found, in addition, the Supreme Court held that Judge Hobbs failed properly to supervise her judicial assistant. The Court further added a fine to the Hearing Panel's discipline recommendation and ordered that Judge Hobbs pay a fine in the amount of $30,000. View "Inquiry Concerning Judge Hobbs" on Justia Law

The Supreme Court affirmed the judgment of the circuit court summarily denying Appellant's third amended successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851 and denying his motion to correct illegal sentence filed pursuant to Fla. R. Crim. P. 3.800(a), holding that there was no error.Appellant was convicted of three counts of first-degree murder, two counts of arson, and grand theft. Appellant was sentenced to death for each murder. The Supreme Court affirmed. Appellant later filed the postconviction motion at issue and a rule 3.800(a) motion arguing that his death sentences were illegal. The circuit court summarily denied the postconviction motion and also denied his rule 3.800(a) motion. The Supreme Court affirmed, holding that Appellant's claims were not timely raised. View "Pittman v. State" on Justia Law