Justia Florida Supreme Court Opinion Summaries

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The Supreme Court approved the holding of the court of appeal that Fla. Const. art. I, 14 does not prohibit the trial court the discretion at first appearance, upon a finding of probable cause that the defendant committed a crime punishable by capital punishment or life imprisonment, to defer ruling on bail and to detain the defendant for a reasonable time to conduct a "full" Arthur bond hearing, holding that there was no error.Defendant was arraigned on one count of robbery using a firearm or deadly weapon. After a hearing held pursuant to State v. Arthur, 390 So. 2d 717 (Fla. 1980) the trial court concluded that the evidence was sufficient to convict Defendant of unarmed robbery and granted him pretrial release and bail in the amount of $25,000. On appeal, Defendant argued that the first sentence of article 1, section 14 creates a two-step procedure. The court of appeals rejected this argument. The Supreme Court affirmed, holding that article I, section 14 does not prohibit a trial court from detaining a defendant beyond first appearance without setting release unless the court has made a preliminary finding that the proof of guilt is evident or the presumption is great. View "Thourtman v. Junior" on Justia Law

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The Supreme Court held that an "Engle progeny" plaintiff must prove reliance on a statement that was made by an Engle defendant for a concealment claim or co-conspirator for a conspiracy claim and that concealed or omitted material information about the addictiveness or health effects of smoking cigarettes.Plaintiff, on behalf of a deceased smoker, brought this wrongful death lawsuit. The jury found that the decedent was a member of the Engle class then found in Plaintiff's favor on her claims for strict liability, negligence, and concealment conspiracy. The court of appeal vacated the judgment, concluding that the trial court's refusal to give Defendant's requested special instruction on reliance was both erroneous and prejudicial. The Supreme Court approved the court of appeal's decision, holding that Defendant's requested jury instruction on concealment conspiracy was correct, and the trial court's instruction was both erroneous and prejudicial. View "Prentice v. R.J. Reynolds Tobacco Co." on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Billy Sheppard Jr.'s motion to vacate his conviction of first-degree murder and denied Sheppard's petition for a writ of habeas corpus, holding that the circuit court properly denied postconviction relief for all guilt claims and that Sheppard failed to establish that he was entitled to habeas corpus relief.Sheppard was convicted of first-degree murder and sentenced to death. Sheppard later filed a motion to vacate his conviction and sentence under Fla. R. Crim. P. 3.851. The circuit court granted a new penalty phase but denied Sheppard's claims as to the guilt phase of his trial. Sheppard appealed, raising claims relevant to the guilt phase, and filed a petition for writ of habeas corpus raising two claims of ineffective assistance of counsel. The Supreme Court affirmed the circuit court's order and denied Sheppard's petition for writ of habeas corpus, holding that Sheppard was not entitled to relief on any of his claims. View "Sheppard v. State" on Justia Law

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The Supreme Court held that Fla. Stat. 120.68(3), which entitles a party to a presumptive stay upon the appeal of an agency decision that "has the effect of suspending or revoking a license," does not apply to an agency decision to administratively withdraw an incomplete renewal license application.When Ybor Medical Injury and Accident Clinic, Inc. (the clinic), applied to the Agency for Health Care Administration (AHCA) to renew its expiring license the AHCA invited the clinic to supplement its application, which was incomplete. After the clinic failed to do so, AHCA administratively withdrew the incomplete renewal license application from further consideration. The AHCA appealed and sought a presumptive stay under section 120.68(3). The court of appeals granted the presumptive stay. The Supreme Court quashed the decision below, holding that the appeal of an agency’s withdrawal decision does not trigger the statute’s presumptive stay provision. View "Agency for Health Care Administration v. Ybor Medical Injury & Accident Clinic, Inc." on Justia Law

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The Supreme Court granted Petitioner's petition for a writ of mandamus compelling the court of appeals to reinstate his appeal of a circuit court order denying him postconviction relief, holding that Petitioner did all that the text of the inmate filing rule required.Petitioner, an inmate convicted of second-degree murder, filed a pro se petition for postconviction relief under Fla. R. Crim. P. 3.850. The circuit court denied the petition. Petitioner appealed, but the court of appeals dismissed the appeal as untimely. Petitioner then filed for relief seeking a writ of mandamus compelling the court of appeals to reinstate his appeal. The Supreme Court granted the petition, holding that the court of appeals erred in not accepting Petitioner's notice of appeal as timely filed without a prison date stamp because the prison mail log produced by Petitioner indicated the notice was timely turned over to prison officials for mailing under Fla. R. App. P. 9.420(a)(2). View "Wade v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's two first-degree murder convictions and two corresponding sentences of death, holding that Defendant was not entitled to relief on his allegations of error.After a trial, a jury found Defendant guilty of two counts of first-degree murder with a firearm. The jury rendered unanimous verdicts recommending a penalty of death on both murder counts, determining that the aggravating factors outweighed the mitigating circumstances. In this direct appeal, Defendant raised fifteen claims, including several challenges to the trial court's evidentiary rulings and to Florida's death penalty scheme. The Supreme Court affirmed Defendant's convictions for first-degree murder and his sentences of death, holding that Defendant failed to establish prejudicial error in any respect. View "Joseph v. State" on Justia Law

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The Supreme Court affirmed Defendant's sentences of death imposed in connection with his conviction for two counts of first-degree murder, holding that Defendant was not entitled to relief on his claims of error.After he was originally convicted and sentenced Defendant received a new penalty phase in light of Hurst v. State, 202 So. 3d 40 (Fla. 2016). Thereafter, Defendant was resentenced to death for both murders. The Supreme Court affirmed Defendant's sentences of death, holding (1) Defendant's jury unanimously found that each of five aggravating factors was proven beyond a reasonable doubt; (2) there was no error in allowing the State to amend its notice of aggravating factors; (3) the trial court did not err in permitting the introduction of victim impact evidence; and (4) Defendant was not entitled to relief on his remaining claims of error. View "McKenzie v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the trial court summarily denying Appellant's sixth successive motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, holding that the trial court did not err in summarily denying Appellant's postconviction motion.Appellant was convicted of first-degree murder, sexual battery, and burglary. The trial judge sentenced Appellant to death. In his sixth successive postconviction motion Appellant asserted two claims, including a claim under Brady v. Maryland, 373 U.S. 83 (1963). The trial court rejected both claims. The Supreme Court affirmed, holding that the trial court did not err in summarily denying Appellant's sixth postconviction motion. View "Booker v. State" on Justia Law

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The Supreme Court held that Plaintiff's unjust enrichment claim failed because he received adequate consideration in exchange for the challenged fee when he took advantage of the privilege of using his credit card to pay the penalty.Plaintiff filed a putative class action arguing that a convenience fee that Plaintiff paid in connection with a penalty he paid with his credit card to the City of North Miami Beach. Plaintiff argued that the convenience fee was statutorily prohibited and that American Traffic Solutions, Inc. (ATS), with whom the City had contracted to issue and mail citations and process violators' payments of the civil penalties imposed, was unjustly enriched by retaining the fee. The trial court dismissed the complaint for failure to state a claim. The court of appeals certified a question to the Supreme Court, which answered that Plaintiff's unjust enrichment claim failed because he had not alleged a benefit conferred and accepted which would be unjust for ATS to retain. View "Pincus v. American Traffic Solutions, Inc." on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder and his sentence of death, holding that there was no error in the proceedings below.Defendant entered a no contest plea to first-degree murder, attempted murder of a correctional officer with a deadly weapon, and other crimes. The trial court sentenced Defendant to death. The Supreme Court affirmed the convictions and sentences, holding (1) the trial court did not abuse its discretion by not employing all of the mitigation-investigation procedures required in Muhammad v. State, 782 So. 2d 343 (Fla. 2001), because Muhammad's investigative procedures did not apply; (2) Defendant's second assignment of error was without merit; and (3) Defendant voluntarily and knowingly entered his no contest plea. View "Bell v. State" on Justia Law

Posted in: Criminal Law