Justia Florida Supreme Court Opinion Summaries

While serving a forty-year sentence at Mayo Correctional Institution, Jesse Bell and his cellmate planned and executed the murder of another inmate as a rehearsal for a subsequent planned attack on a correctional officer. On June 26, 2019, they killed the inmate and later that day attempted to kill the officer, who survived. Bell confessed to the crimes and was indicted for first-degree murder, attempted murder, conspiracy, and possession of contraband. Shortly after counsel was appointed, Bell waived his right to counsel and a penalty-phase jury, entered a no-contest plea, and represented himself during sentencing. The court found multiple aggravating factors and sentenced Bell to death.The Circuit Court for Lafayette County conducted the trial and sentencing. On direct appeal, the Supreme Court of Florida affirmed Bell’s conviction and death sentence, finding his waivers and plea were knowing and voluntary, and that he was not deprived of an individualized sentencing. Bell then filed a motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, arguing his waivers were involuntary due to prison abuse, that counsel was ineffective for not investigating this abuse, and that he was denied individualized sentencing. The circuit court summarily denied the motion, finding the claims procedurally barred or refuted by the record.The Supreme Court of Florida reviewed the summary denial and Bell’s habeas petition. The court held that Bell’s postconviction claims were procedurally barred because they could have been raised on direct appeal, and that the record showed his waivers were voluntary. The court also found no ineffective assistance of counsel or appellate counsel, as there was no evidence of prejudice or deficient performance. The order denying postconviction relief was affirmed, and habeas relief was denied. View "Bell v. State of Florida" on Justia Law

In 1982, Kayle Barrington Bates committed a series of violent crimes, including robbery, attempted sexual battery, and the murder of Janet Renee White. Bates was apprehended near the scene shortly after the attack, and physical evidence, as well as his own admissions, linked him to the crimes. He was charged with first-degree murder, kidnapping, attempted sexual battery, and armed robbery. A jury found him guilty on all counts and recommended a death sentence.After his initial conviction and sentencing, the Supreme Court of Florida affirmed the convictions but vacated the death sentence due to insufficient evidence supporting two aggravating factors, remanding for resentencing. On remand, the trial court again imposed the death penalty, which the Supreme Court of Florida affirmed. Bates pursued multiple rounds of postconviction relief in both state and federal courts, raising various constitutional and evidentiary claims, all of which were denied. His most recent efforts included a fourth successive postconviction motion and a petition for a writ of habeas corpus, following the signing of a new death warrant.The Supreme Court of Florida, exercising its mandatory review jurisdiction, affirmed the circuit court’s summary denial of Bates’ fourth successive postconviction motion and the denial of his public records requests. The court found Bates’ claims to be untimely, procedurally barred, or previously litigated and rejected. The court also denied his habeas petition, finding all claims either procedurally barred or without merit. The court denied Bates’ requests for a stay of execution and oral argument, and ordered that no motion for rehearing would be considered, with the mandate to issue immediately. The main holding is that Bates is not entitled to postconviction or habeas relief, and his execution may proceed. View "Bates v. State" on Justia Law

Edward J. Zakrzewski, II, was sentenced to death for the murders of his wife, Sylvia, and two minor children, Edward and Anna, which he committed on June 9, 1994. Zakrzewski pled guilty to all three murders and was sentenced to death for each, with the trial court overriding the jury's recommendation of life imprisonment for Anna's murder. The trial court found three aggravating factors for each murder and gave significant weight to both statutory and nonstatutory mitigators.On direct appeal, the Florida Supreme Court affirmed Zakrzewski’s convictions and sentences. The United States Supreme Court denied certiorari review, making the sentences final. Over the next three decades, Zakrzewski sought postconviction relief multiple times in both state and federal courts, all of which were denied. His federal habeas petition was denied by the Northern District of Florida, and the Eleventh Circuit Court of Appeals affirmed the denial. Zakrzewski also filed several motions for postconviction relief under Florida Rule of Criminal Procedure 3.851, all of which were denied by the Florida Supreme Court.Governor Ron DeSantis signed Zakrzewski’s death warrant on July 1, 2025, setting an execution date of July 31, 2025. Zakrzewski filed his fifth successive motion for postconviction relief, raising three claims, which the Circuit Court of the First Judicial Circuit summarily denied. Zakrzewski appealed the denial, raising four arguments.The Supreme Court of Florida affirmed the circuit court’s summary denial of Zakrzewski’s fifth successive postconviction motion. The court found Zakrzewski’s claims untimely, procedurally barred, and meritless. The court also rejected Zakrzewski’s claims regarding the Governor’s discretion in signing death warrants and the lack of a recent clemency review. Additionally, the court upheld the circuit court’s denial of Zakrzewski’s requests for public records, finding no abuse of discretion. The court denied Zakrzewski’s motion for a stay of execution and request for oral argument. View "Zakrzewski v. State" on Justia Law

A defendant was convicted of first-degree felony murder, aggravated child abuse, and sexual battery following the 1992 death of a two-year-old child. The evidence at trial showed that the defendant was alone with the victim, who was later found unconscious, with visible injuries and blood present in the apartment and on the defendant’s clothing. The medical examiner concluded the cause of death was a cerebral hemorrhage from multiple blows to the head. The defendant claimed the child’s injuries were accidental or caused by another individual, but the jury rejected this defense and recommended a death sentence, which was imposed.After the conviction and sentence were affirmed by the Supreme Court of Florida, the defendant filed several postconviction motions and habeas petitions, all of which were denied. In the most recent proceedings, the defendant filed a fourth successive motion for postconviction relief in the Circuit Court for Duval County. The motion argued that microscopic slides from the autopsy constituted newly discovered evidence and that the State had suppressed exculpatory information in violation of Brady v. Maryland. The circuit court summarily denied the motion, finding the claims untimely and without merit, noting that the existence of the slides and the finding of pneumonia were disclosed in the original autopsy report and available to the defense.On appeal, the Supreme Court of Florida reviewed the summary denial de novo. The court held that both the Brady and newly discovered evidence claims were untimely because the defendant knew or could have known of the evidence with due diligence. The court further held that no evidence was suppressed and that the new expert’s conclusions did not meet the standards for materiality or probability of acquittal required for relief. The court affirmed the summary denial of postconviction relief. View "Davis v. State of Florida" on Justia Law

Florida Power & Light Company (FPL) entered into a multi-party settlement agreement to establish base rates, which was approved by the Florida Public Service Commission (Commission). The settlement allowed FPL to increase rates annually for four years, generating significant additional revenue and permitting incremental rate increases for solar projects. It also included provisions for an equity-to-debt ratio, return on equity, and a minimum base bill for customers. The settlement aimed to support investments in power generation, transmission, distribution systems, and renewable energy programs.The Commission's initial approval of the settlement was challenged, leading to a remand by the Supreme Court of Florida in Floridians Against Increased Rates, Inc. v. Clark (FAIR). The Court required the Commission to provide a more detailed explanation of its reasoning and to consider FPL's performance under the Florida Energy Efficiency and Conservation Act (FEECA). On remand, the Commission denied a motion to reopen the evidentiary record and issued a Supplemental Final Order, reaffirming that the settlement was in the public interest.The Supreme Court of Florida reviewed the case again. The Court upheld the Commission's approval of the settlement, finding that the Commission's factual findings were supported by competent, substantial evidence and that its policy decisions were within its discretion. The Court concluded that the Commission had adequately considered the mandatory and discretionary factors, including FPL's FEECA performance, and provided a reasoned explanation for its decision. The Court affirmed the Commission's Final and Supplemental Final Orders, determining that the settlement established fair, just, and reasonable rates. View "Florida Rising, Inc. v. Florida Public Service Commission" on Justia Law

The case involves a challenge to Florida’s 2022 congressional districting plan. The plaintiffs, consisting of civic organizations and individual voters, argue that the plan violates the Florida Constitution's Fair Districts Amendment (FDA) by failing to retain a two-hundred-mile-long congressional district that previously enabled black voters in North Florida to elect representatives of their choice. The plaintiffs claim that the new plan diminishes this ability, contrary to the FDA's Non-Diminishment Clause.The trial court ruled in favor of the plaintiffs, declaring the Enacted Plan unconstitutional under the FDA, enjoining its use, and ordering the Legislature to adopt a remedial map. The First District Court of Appeal reversed this decision, holding that the plaintiffs failed to prove the existence of a sufficiently compact minority community in North Florida to merit protection under the FDA. The appellate court also questioned the binding nature of the Florida Supreme Court’s precedents on the Non-Diminishment Clause.The Supreme Court of Florida reviewed the case and upheld the Enacted Plan. The court concluded that the plaintiffs did not meet their burden of proving the possibility of drawing a North Florida district that complies with both the Non-Diminishment Clause and the Equal Protection Clause. The court emphasized that compliance with the Equal Protection Clause is a superior obligation and that the plaintiffs failed to demonstrate that a non-diminishing district could be drawn without subordinating traditional race-neutral districting principles to racial considerations. Consequently, the court affirmed the judgment of the First District Court of Appeal, though not its reasoning. View "Black Voters Matter Capacity Building Institute, Inc. v. Secretary, Florida Department of State" on Justia Law

An individual was convicted of the 2010 first-degree felony murder of an elderly woman, Janet Patrick, after being seen with her at a grocery store and later found in possession of her car and credit cards. The victim’s body was discovered in a wooded area, and forensic evidence linked the defendant to the crime scene and the victim’s vehicle. The defendant was also charged with robbery and kidnapping. His defense at trial was based on claims of mental illness or seizures. The jury found him guilty on all counts.The Florida Supreme Court previously affirmed the convictions and non-capital sentences but reversed the death sentence because the jury’s recommendation was not unanimous, as required by Hurst v. State. After subsequent legal developments, including State v. Poole and State v. Okafor, the defendant was granted a new penalty phase. During the new penalty phase, the defendant represented himself, waived a jury trial, and declined to present mitigation evidence. The trial court denied his motion for a continuance to secure a new mitigation specialist, finding that he had been given multiple opportunities to obtain such assistance. The court ultimately sentenced him to death, finding four aggravating factors and several mitigating circumstances.On direct appeal, the Supreme Court of Florida reviewed four claims: denial of the motion to continue, voluntariness of waivers of jury and mitigation, access to discovery, and the constitutionality of Florida’s death penalty scheme. The court held that the trial court did not abuse its discretion in denying the continuance, that the waivers were knowing and voluntary, that discovery obligations were met, and that the capital sentencing scheme was constitutional. The court affirmed the sentence of death. View "Williams v. State of Florida" on Justia Law

In April 2011, JJJTB, Inc. initiated a foreclosure action against Stephen Schmidt and Schmidt Farms, Inc. in Hillsborough County. In 2015, the Thirteenth Judicial Circuit denied the foreclosure judgment, and the Second District Court of Appeal affirmed this decision. Over two years later, JJJTB amended its complaint to include new defaults. Schmidt moved to dismiss the amended complaint but did not argue lack of case jurisdiction. The trial court denied the motion, and Schmidt filed an answer with affirmative defenses and a counterclaim but again did not raise the issue of case jurisdiction. In 2021, the court entered a foreclosure judgment against Schmidt, who then unsuccessfully moved for rehearing, asserting lack of subject matter jurisdiction.Schmidt appealed to the Second District Court of Appeal, arguing the trial court lacked jurisdiction. The Second District reversed the foreclosure judgment, holding that the trial court lacked case jurisdiction and that such objections cannot be waived. The court certified conflict with the Fourth District Court of Appeal's decision in MCR Funding v. CMG Funding Corp., which held that case jurisdiction is waivable.The Supreme Court of Florida reviewed the case to resolve the conflict. The court held that case jurisdiction is waivable and that objections must be timely raised, or they are waived. The court quashed the Second District's decision and approved the Fourth District's decision in MCR Funding. The Supreme Court concluded that Schmidt waived the objection to the trial court's lack of case jurisdiction by not raising it timely and by seeking affirmative relief. The Second District erred in reversing the foreclosure judgment based on untimely objections to case jurisdiction. View "JJJTB, Inc. v. Schmidt" on Justia Law

Anthony Rojas, a student at the University of Florida, filed a class action lawsuit against the University of Florida Board of Trustees. Rojas claimed that the University breached its contract by suspending on-campus services and closing facilities during the COVID-19 pandemic, despite students being required to pay mandatory fees for these services. He also alleged that the University failed to refund these fees. The complaint included a spring 2020 tuition statement, a general statement of tuition and fee estimates for the 2019-2020 academic year, and the University’s financial liability agreement.The trial court dismissed the unjust enrichment claim but denied the University’s motion to dismiss the breach of contract claim, ruling that the complaint adequately pleaded the existence of an express contract. The University appealed, and the First District Court of Appeal reversed the trial court’s decision, holding that the claims were barred by sovereign immunity. The First District concluded that the contract alleged by Rojas did not constitute an express written contract sufficient to overcome sovereign immunity.The Supreme Court of Florida reviewed the case and quashed the First District’s decision. The Court held that the waiver-by-contract doctrine does not preclude claims based on the breach of implied covenants or conditions that do not conflict with express contract provisions. The Court found that the First District erred in requiring extraordinary specificity in government contracts and in failing to recognize permissible implied covenants. The case was remanded for further proceedings consistent with this opinion. View "Rojas v. University of Florida Board of Trustees" on Justia Law

In 2009, Timothy W. Fletcher was convicted of first-degree murder for the death of Helen Googe. Fletcher and his cellmate, Doni Ray Brown, escaped from jail and went to Googe’s home to steal money. Fletcher confessed to his involvement, although he initially claimed Brown was the primary aggressor. The physical evidence, including DNA under Googe’s fingernails, linked Fletcher to the crime. The jury found Fletcher guilty and recommended the death penalty by a vote of eight to four.Fletcher’s initial death sentence was vacated due to a non-unanimous jury recommendation, and he was granted a new penalty phase under Hurst v. State. During the new penalty phase, the State presented evidence to support four aggravating factors, while Fletcher presented evidence of forty-nine mitigating circumstances. The jury unanimously found all four aggravating factors and recommended the death penalty. The trial court merged two aggravators and found three aggravating factors, giving them great weight, and considered fifty-two mitigating factors, giving moderate weight to the cumulative mitigation.Fletcher appealed to the Supreme Court of Florida, raising nine issues, including claims of prosecutorial misconduct, jury nullification, and the constitutionality of Florida’s capital sentencing scheme. The court found no reversible error, concluding that the prosecutor’s comments did not improperly denigrate mitigating evidence, the jury followed instructions, and the victim impact evidence was admissible. The court also rejected Fletcher’s constitutional challenges to the death penalty statute and the aggravating factors applied in his case. The court affirmed Fletcher’s death sentence, finding that the trial court properly weighed the aggravating and mitigating factors and that the jury’s recommendation was supported by the evidence. View "Fletcher v. State of Florida" on Justia Law