Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the trial court denying Defendant's claims that he was intellectually disabled and therefore ineligible for the death penalty and that he was entitled to relief under Hurst v. Florida, 577 U.S. 92 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016), holding that there was no error.Defendant was convicted and sentenced in death in 1985 for first-degree murder. Before the Supreme Court in this case was Defendant's successive motion under Fla. R. Crim. P. 3.203 raising an intellectual disability claim. The trial court denied the claim, concluding that Defendant had not established intellectual disability and that Defendant was not entitled to relief under Hurst. The Supreme Court affirmed, holding that Defendant failed to establish that he was entitled to relief. View "Nixon v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeal that invited error precluded review of Defendant's claim on appeal that a jury charge was coercive, holding that the court of appeal did not err.Defendant was convicted of manslaughter with a deadly weapon, two counts of attempted manslaughter, and unlawful possession of a firearm by a minor. Defendant appealed, arguing that the jury's verdict was coerced by the trial court's issuance of a second modified Allen charge, which defense counsel requested. The court of appeal affirmed, concluding that although the charge was coercive, Defendant waived the error by agreeing to the modified charge. The Supreme Court affirmed, holding that the invited error precluded review for fundamental error. View "Baptiste v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Gary Hilton's motion to vacate his conviction of first-degree murder and sentence of death and denied Hilton's petition for a writ of habeas corpus, holding that Hilton was not entitled to relief.Specifically, the Supreme Court held (1) as to Hilton's claims of ineffective assistance of counsel, Defendant's allegations of deficient performance were insufficient to satisfy Strickland, and the postconviction court did not err in denying Hilton's claim that he was entitled to relief under Hurst v. Florida, 577 U.S. 92 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016); and (2) as to Hilton's petition for writ of habeas corpus, some claims were procedurally barred and, as to his remaining claims, Hilton was not entitled to relief. View "Hilton v. State" on Justia Law

The Supreme Court affirmed Defendant's judgment of conviction of first-degree murder and sentence of death, holding that Defendant failed to demonstrate error on the part of the trial court.Specifically, the Supreme Court held (1) the trial court did not commit fundamental error by failing to find beyond a reasonable doubt that sufficient aggravating circumstances existed and that those circumstances outweighed the mitigating circumstances; (2) there was no merit to Defendant's challenges to the trial court's handling of mitigating evidence; (3) Defendant's challenge to the constitutionality of the prior-violent-felony aggravator was unavailing; and (4) Defendant's guilty plea was voluntarily and knowingly given. View "Davidson v. State" on Justia Law

The Supreme Court affirmed the order of the trial court summarily dismissing Defendant's successive motion for postconviction relief, holding that the trial court did not err.Defendant pleaded guilty to two counts of first-degree murder and was sentenced to death. The Supreme Court affirmed on direct appeal. When his convictions and sentences had been final for more than twenty-three years Defendant filed the instant successive postconviction motion under Fla. R. Crim. P. 3.851, raising five claims. The trial court summarily dismissed the successive motion. The Supreme Court affirmed, holding (1) the trial court did not err in dismissing four of Defendant's claims as untimely; and (2) Defendant's claim that his death sentences violated the Sixth and Fourteenth Amendments in light of Hurst v. Florida, 577 U.S. 92 (2016), was both untimely and without merit. View "James v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree murder but reversed his sentence of death and remanded for the limited purpose of resentencing and a new sentencing order, holding that the trial court improperly relied on facts not in the record in sentencing Defendant to death.Specifically, the Supreme Court held (1) the trial court impermissibly relied on non record evidence from the trial of Defendant's codefendant in finding that Defendant was the shooter in this case and sentencing him to death; and (2) Defendant was not entitled to relief on his remaining claims of error. The Supreme Court remanded the case for the limited purpose of requiring the trial court to perform a new sentencing evaluation and provide a new sentencing order. View "Cruz v. State" on Justia Law

The Supreme Court quashed the decision of the Fourth District Court of Appeal in this juvenile sentencing case remanding for the trial judge to remedy a harmful Alleyne error through a "ministerial correction" of sentence for which the defendant "need not be present," holding that the remedy fell short of the de novo sentencing required by Williams v. State, 242 So. 3d 280 (Fla. 2018).At issue was the proper remedy for a harmful Alleyne error that occurs where, in sentencing a juvenile offender under Fla. Stat. 775.082(1)(b), the trial court enhances the sentence without a jury finding of the fact that authorizes the enhancement. In this case, Defendant, who committed two homicides, argued that he should be resentenced because the jury was not asked to find, and did not find, that he "actually killed, attempted to kill, or intended to kill the victims," as required under section 775.082(1)(b)1. The Fourth District concluded that the trial court committed a harmful Alleyne error in resentencing Defendant and remanded for "ministerial correction" of Defendant's sentences, for which Defendant "need not be present[.]" The Supreme Court quashed the Fourth District's decision, holding that Defendant was entitled to the de novo resentencing required by Williams. View "Puzio v. State" on Justia Law

In this foreclosure case, the Supreme Court quashed the decision of the Third District Court of Appeal failing to follow precedent and concluding that the term "Borrower" means something different than both the mortgage and the note define it to mean, holding that the court of appeal erred in affirming the trial court's denial of foreclosure.Petitioner's predecessor sought to foreclose on a mortgage that secured the loan. Respondents, Luisa Palmero and her children, defended against the foreclosure action by arguing that Luisa was not a co-borrower under the mortgage. The trial court ruled that Luisa was not a co-borrower but denied foreclosure based on a federal statute. The Third District held that the trial court erred by relying on the federal statute to deny foreclosure and ruled that, as a matter of law, the mortgage unambiguously defined Luisa as a "Borrower." Thus, the Third District affirmed the denial of foreclosure. The Supreme Court reversed, holding that the Third District erred in affirming the trial court's denial of foreclosure on the ground that, as a matter of law, Luisa was a surviving co-borrower. View "WVMF Funding v. Palmero" on Justia Law

The Supreme Court affirmed the sentence of death that was imposed at Defendant's resentencing for the first-degree murder of Seath Jackson, holding that Defendant's claims of error were unavailing.The Supreme Court previously affirmed Defendant's conviction for first-degree murder with a firearm but vacated his sentence of death and remanded for a new penalty phase based on Hurst v. State, 202 So. 3d 40 (Fla. 2016). After a new penalty phase, the judge again imposed a sentence of death. The Supreme Court affirmed, holding (1) the State was not precluded from seeking the death penalty; (2) Defendant's argument that the court erred in allowing evidence of post-death acts was not adequately preserved for review; (3) the circuit court did not abuse its discretion in assigning little or no weight to mental mitigation factors; (4) the circuit court properly considered Defendant's age and certain other mitigating circumstances; and (5) the death sentence was not disproportionate. View "Bargo v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's motion for a determination of intellectual disability as a bar to execution and his amended successive motion for postconviction relief, holding that relief was properly denied.Appellant was convicted of murder and sentenced to death. Appellant later filed a successive motion for postconviction relief seeking to vacate his death sentence on the ground that he was intellectually disabled. Appellant also brought claims under Hurst v. Florida, 577 U.S. 92 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The trial court ultimately denied Appellant's intellectual disability and Hurst-related claims. The Supreme Court affirmed, holding that the trial court did not err in denying relief. View "Haliburton v. State" on Justia Law