Justia Florida Supreme Court Opinion Summaries

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

The Supreme Court approved the Second District Court of Appeal's decision in this negligence case, holding that the ruling in Joerg v. State Farm Mutual Insurance Co., 176 So,. 3d 1247 (Fla. 2015) prohibiting the introduction of evidence of Medicare benefits in a personal injury case for purposes of a jury's consideration of future medical expenses does not also apply to past medical expenses.Plaintiff sought to recover past medical expenses due to injuries she received when she tripped and fell on property owned by Defendant. The jury awarded Plaintiff $34,642 in past medical expenses. On appeal, Plaintiff argued that the trial court abused its discretion by precluding her from introducing as evidence the gross amount of her past medical expenses and limited her to introducing only the discounted amounts paid by Medicare. The Second District affirmed, concluding that the Joerg court set the scope of its holding to evidence concerning future Medicare benefits. The Supreme Court affirmed, holding that Jeorg had no application to the past medical expenses at issue in the instant case. View "Dial v. Calusa Palms Master Ass'n" on Justia Law

The Supreme Court held that the statutory presuit notice requirement that Fla. Stat. 766.106 imposes on a claimant who seeks to file a medical negligence suit demands only that a claimant to timely mail the presuit notice to trigger tolling of the applicable limitations period.The claimant in this case mailed the presuit notice before the expiration of the applicable limitations period, but the defendant did not receive the notice until after the limitations period would have expired, absent tolling. At issue was whether the limitations period for filing a medical negligence complaint is tolled under section 766.106(4) upon the claimant's mailing of the presuit notice of intent to initiate litigation or only upon the prospective defendant's receipt of the notice. The Supreme Court held that under section 766.106 and Fla. R. Civ. P. 1.650, it is the timely mailing of the presuit notice of intent to initiate ligation, rather than the defendant's receipt of the notice, that begins the tolling of the applicable limitations period for filing a complaint for medical negligence. View "Boyle v. Samotin" on Justia Law

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