Justia Florida Supreme Court Opinion Summaries

The Supreme Court held that when a defendant voluntarily chooses to allocate at a sentencing hearing, the sentencing court is permitted to consider the defendant's freely offered statements, including those indicating the defendant's failure to accept responsibility.On appeal from the judgment of the trial court in this case, the First District concluded that "lack of remorse and refusal to accept responsibility can be valid sentencing considerations when sentencing within the statutory range." The Supreme Court approved the result in the decision on review, holding that the sentencing judge in this case was entitled to consider testimony that indicated Defendant's unwillingness to accept the truth and to take responsibility for his conduct. View "Davis v. State" on Justia Law

The Supreme Court sanctioned Petitioner after dismissing his petition for a writ of habeas corpus, holding that Petitioner failed to show cause why he should not be barred from filing any further pro se requests for relief.Since 2018, Petitioner, who was convicted of false imprisonment and aggravated battery, had filed sixteen petitions with the Supreme Court, including the petition at issue in this case, all without success. The Supreme Court dismissed the instant petition as a repetitive claim and held that, based on Petitioner's history of filing pro se petitions and requests for relief that were meritless or otherwise inappropriate for review, the clerk of court should reject any future pleadings or requests for relief submitted by Petitioner pertaining to his criminal case. View "Martin v. Dixon" on Justia Law

The Supreme Court approved the stipulation entered into by Palm Beach County Judge Marni Bryson and the Florida Judicial Qualifications Commission (JQC) that Judge Bryson be publicly reprimanded, suspended without pay for ten days, and pay a $37,500 fine, concluding that Judge Bryson acted inappropriately by failing to devote full time to her judicial duties.The JQC found that Judge Bryson was absent from the courthouse beyond the permitted number of days for judicial leave, failed to make appropriate notifications of some absences to appropriate court management, and was sometimes in the courthouse for less than a full workday. Judge Bryson admitted her conduct in the stipulation, and the JQC found that Judge Bryson's actions violated Canons 3A and 3B(4) for the Florida Code of Judicial Conduct. The Supreme Court approved the stipulation of the parties and ordered that Judge Bryson be publicly reprimanded and pay a $37,500 fine. View "Inquiry Concerning Judge Marni A. Bryson" on Justia Law

The Supreme Court approved the holding of the Second District Court of Appeal in this case, which involved an appeal of a conviction for driving as a habitual traffic offender (HTO) while one's driver's license is revoked (DWLR-HTO), holding that the court below reached the correct result.The district court held that, under Fla. Stat. 322.34(5), a conviction for DWLR-HTO does not require the State to prove that the Florida Department of Highway Safety and Motor Vehicles (DHSMV) provided Defendant with notice of the HTO driver license revocation. The Supreme Court approved the district court's ruling, holding that proof that DHSMV provided a defendant with notice of an HTO driver license revocation is not an element of the crime of DWLR-HTO under section 322.34(5). View "Robinson v. State" on Justia Law

The Supreme Court held that the wrongful death action at issue in this case was covered by the Legislature's 1999 amendment of Fla. Stat. 768.73.In 1999, the Legislature amended section 768.73 to presumptively preclude an award of punitive damages against a defendant in a civil action if “punitive damages have previously been awarded against that defendant in any state or federal court in any action alleging harm from the same act or single course of conduct for which the claimant seeks compensatory damages" and made the amendments applicable "to all causes of action arising after" October 1, 1999. The certified conflict at issue in this case was whether the amendments applied to Engle progeny wrongful death actions where the smoking-injured decedent died after October 1, 1999. The Fifth District Court of Appeal held that the 1999 amendments applied to Petitioner's Engle progeny wrongful death action against Respondent, on which "numerous prior punitive damages awards" had been imposed previously. The Supreme Court affirmed, holding that the 1999 amendments apply in Engle progeny wrongful death actions in which the decedent died after the effective date of the amendments. View "Sheffield v. R.J. Reynolds Tobacco Co." on Justia Law

The Supreme Court approved the decision of the First District Court of Appeal in this case, holding that Fla. Stat. 942.051(3), which prohibits raising an unpreserved claim of error on direct appeal absent a showing of fundamental error, precludes appellate review of unpreserved claims of ineffective assistance of trial counsel on direct appeal.Defendant was found guilty of first-degree murder. On appeal, Defendant argued that he received ineffective assistance of counsel. The First District affirmed Defendant's convictions and sentence and declined to address his claims of ineffective assistance because he did not preserve any of the errors he advanced on appeal and did not make a claim of fundamental error. The Supreme Court approved of the decision below, holding that the plain text of section 924.051 prohibits raising unpreserved error on direct appeal absent a showing of fundamental error. View "Steiger v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death, holding that Defendant's arguments on appeal were unavailing.Specifically, the Supreme Court held that the trial court did not abuse its discretion in granting Defendant's request for self-representation because (1) a competency hearing was not required; (2) substantial evidence supported the findings that Defendant's waiver of the right to counsel was knowing, voluntary, and intelligent under Faretta v. California, 422 U.S. 806; and (3) the trial court was not required to find that Defendant suffered from severe mental illness to the point that he was incompetent to conduct trial proceedings by himself. View "Noetzel v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's third successive motion for postconviction relief, filed under Fla. R. Crim. P. 3.851, holding that there was no error.Appellant was convicted of first-degree murder, armed robbery, and grand theft of a motor vehicle. The trial court sentenced Defendant to death. After the Supreme Court affirmed Appellant sought postconviction relief in both state and federal court, without success. At issue was Appellant's third successive postconviction motion in which he raised a single claim of newly discovered evidence based on alleged childhood sexual abuse. The circuit court summarily denied the motion. The Supreme Court affirmed, holding that the circuit court did not err in denying Appellant's postconviction motion without first holding an evidentiary hearing. View "Rogers v. State" on Justia Law

The Supreme Court affirmed the judgment of the postconviction court denying Defendant's petition for postconviction relief as to the guilt phase of his trial and denied his petition for a writ of habeas corpus, holding that Defendant was not entitled to relief.Defendant was convicted of three counts of first-degree murder and sentenced to death for two of the murders. The Supreme Court affirmed. Defendant later filed a motion for postconviction relief, raising sixteen claims. The trial court granted in limited part Defendant's motion for postconviction relief as to a new penalty phase under Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court affirmed, holding (1) the postconviction court did not err in denying Defendant's motion for postconviction relief as to the guilt phase; and (2) Defendant failed to establish that he was entitled to a writ of habeas corpus. View "Smith v. State" on Justia Law

The Supreme Court answered in the negative a question certified to it by the Fourth District Court of Appeal, holding that it is not a departure from the essential requirements of law to permit discovery regarding the financial relationship between a defendant's nonparty insurer and an expert witness retained by the defense.This case involved a discovery dispute in an automobile negligence action. Plaintiff sought to discover from Defendant the financial relationship between Defendant's nonparty insurer and his expert witness. Defendant was ordered to provide the discovery. Defendant then filed a petition for writ of certiorari. The Fourth District denied the writ but certified a question to the Supreme Court. The Supreme Court answered the question in the negative, thus approving the result reached by the Fourth District, and declined to readdress its holding or analysis adopted in Worley v. Central Florida Young Men's Christian Ass'n, 228 So. 3d 18 (Fla. 2017). View "Dodgen v. Grijalva" on Justia Law