Justia Florida Supreme Court Opinion Summaries

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

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.In this automobile negligence case, the district court passed upon a question that it certified to be of great public importance regarding whether the Supreme Court's decision in Worley v. Central Florida Young Men's Christian Ass'n, 228 S. 3d 18 (Fla. 2017), forecloses discovery of the financial relationship between a personal injury defendant's nonparty law firm and the defendant's expert witnesses. 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 "Younkin v. Blackwelder" on Justia Law

The Supreme Court granted the petition of The Florida Bar to enjoin Respondents, TIKD Services, LLC and Christopher Riley (collectively TIKD) from engaging in the unauthorized practice of law, holding that TIKD was engaged in the unauthorized practice of law and was permanently enjoined from engaging in such acts in the future.The Bar filed a two-count petition against TIKD alleging that it engaged in the unauthorized practice of law and that it held itself out to the public as qualified to provide legal services. The referee filed a report recommending that the Supreme Court dismiss the Bar's petition with prejudice, concluding that TIKD was not engaged in the unauthorized practice of law. The Supreme Court disapproved of the referee's recommendation and ordered that TIKD was permanently and perpetually enjoined from engaging in the unauthorized practice of law in the State. View "Florida Bar v. TIKD Services LLC" on Justia Law

The Supreme Court approved the holding of the First District Court of Appeal concluding that a defendant convicted by a jury verdict after raising a self-defense claim is not entitled to a new immunity hearing if the trial court applied the incorrect standard at the hearing under Fla. Stat. 776.032, holding that the First District did not err.Under 776.032, Florida's Stand Your Ground law, a person is generally immune from criminal prosecution and civil action when that person justifiably uses or threatens to use force under certain circumstances. At issue in this case was the proper remedy for the application of an incorrect burden of proof at an immunity hearing. The First District affirmed Defendant's conviction and sentence but certified conflict with Nelson v. State, 295 So. 3d 307 (Fla. 2d DCA 2020), in which the Second District held that a defendant is entitled to a new immunity hearing after the trial court erroneously applied the burden of proof in his immunity hearing, even though he had subsequently been convicted by a jury. The Supreme Court affirmed and disapproved the decision of the Second District in Nelson. View "Boston v. State" on Justia Law

In this action filed by Samuel Levy seeking to compel his former wife, Einath Levy, to comply with the parties' property settlement and support agreement (PSA), the Supreme Court quashed the decision of the Third District Court of Appeal affirming the judgment of the trial court denying Einath's request for prevailing-party attorney's fees pursuant to Fla. Stat. Ann. 57.105(7), holding that section 57.105(7) did not apply to the attorney's fee provision in this case.In 2011, the marriage of Samuel and Einath was dissolved. The judgment incorporated two agreements between the parties, including the PSA. Each agreement included an attorney's fee provision. Later, Samuel filed a motion to compel Einath to comply with the PSA and requested attorney's fees based on the fee provision in the PSA. Einath, in turn, requested attorney's fees for defending the motion. The magistrate concluded that Einath prevailed in defending against the motion but denied her request for fees under the PSA. The Third District reversed in part, concluding that section 57.105(7) required that Einath be awarded attorney's fees. The Supreme Court quashed the decision of the Third District, holding that section 57.105(7) did not apply to the attorney's fee provision in this case. View "Levy v. Levy" on Justia Law