Justia Florida Supreme Court Opinion Summaries

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

The Supreme Court quashed in part the decision of the Fourth District Court of Appeal affirming the trial court's dismissal of Appellant's mandamus and certiorari claims and reversing as to Plaintiffs' claims for injunctive and declaratory relief, holding that the appellate court erred in reinstating these claims.Plaintiffs brought this action against the City of West Palm Beach seeking injunctive relief requiring the City to investigate and, if necessary, take enforcement action against an alleged zoning violation. The trial court dismissed all of Plaintiffs' claims against the City. The Fourth District affirmed the trial court's dismissal of Plaintiffs' mandamus and certiorari claims but reversed as to their claims for injunctive and declaratory relief. The Supreme Court quashed the Fourth D/istrit's decision in part, holding that an injunction was not available to compel the City to enforce its zoning ordnance against the third party in this case. View "City of West Palm Beach, Inc. v. Haver" on Justia Law

The Supreme Court quashed the decision of the Fifth District Court of Appeal concluding that the circuit court lacked jurisdiction to impose a sexual predator designation on an offender who qualified under the Florida Sexual Predators Act, Fla. Stat. 775.21, when the sentencing court did not impose the designation at sentencing and the offender's sentence had been completed, holding that the Fifth District erred.In 2009, Defendant was sentenced to six months' incarceration, followed by two years of sex offender community control, followed by three years of sex offender probation. In 2015, Defendant completed all portions of his sentence. In 2018, the State filed a notice stating that Defendant's original offense was an enumerated offense under section 775.21, thus obligating the trial court to designate Defendant as a sexual predator. The trial court determined that Defendant must comply with the registration requirements because section 775.21 placed an obligation on the court to designate Defendant as a sexual predator. The Fifth District reversed. The Supreme Court reversed, holding that section 775.21 confers jurisdiction on a trial court to designate a sexual predator after he is sentenced and completes his probation. View "State v. McKenzie" on Justia Law

The Supreme Court held that, for purposes of calculating whether a plaintiff has met the threshold amount of difference between an offer of judgment and the judgment entered for purposes of Fla. Stat. 768.79, post-offer prejudgment interest must be excluded from the amount of the "judgment entered."The Fourth District held that caselaw required the exclusion of post-offer prejudgment interest from the "judgment obtained" when determining entitlement to attorney's fees under section 768.79. Because this conclusion conflicted with the Third District's decision in Perez v. Circuit City Stores, Inc., 721 So. 2d 409 (Fla. 3d DCA 1998), and the First District Court of Appeal’s decision in Phillips v. Parrish, 585 So. 2d 1038 (Fla. 1st DCA 1991), the Fourth District certified conflict. The Supreme Court approved the Fourth District decision and disapproved the decisions in Perez and Phillips to the extent they were inconsistent with the decision today, holding that the Fourth district's interpretation of section 768.79 was not erroneous. View "CCM Condominium Association, Inc. v. Petri Positive Pest Control, Inc." on Justia Law

The Supreme Court affirmed Defendant's judgments of conviction of first-degree murder and sentences of death, holding that there was no prejudicial error in the proceedings below.Defendant was convicted and sentenced to death for his role in a 2016 triple homicide. The Supreme Court affirmed the convictions and sentences, holding (1) certain prosecutorial comments challenged by Defendant did not constitute fundamental error; (2) the trial court did not err in permitting the use of a map as a demonstrative aid; (3) there was no error in the State's presentation of victim impact evidence; and (4) the evidence was sufficient to support the convictions. View "Alcegaire v. State" on Justia Law

The Supreme Court approved the decision of the First District Court of Appeal affirming Defendant's conviction of of three counts of sexual battery and one count of lewd or lascivious exhibition, holding that the schedule of lesser included offenses promulgated by the Florida Supreme Court in 2018 incorrectly classified sexual battery as a necessarily lesser included offense of capital sexual battery.On appeal, Defendant argued that the trial court erred in denying his motion to instruct the jury on sexual battery as a category one, necessarily lesser included offense of capital sexual battery. The First District affirmed. The Supreme Court affirmed, holding that sexual battery is not a necessarily lesser included offense of capital sexual battery. View "Allen v. State" on Justia Law

The Supreme Court approved the decision of the Second District Court of Appeal invalidating the decision of a property appraiser assessing back taxes after discovering his purported clerical error in undervaluing and undertaxing a taxpayer's property, holding that the district court did not err.After discovering valuation errors, the property appraiser reassessed the taxpayer's property and sent her a bill for back taxes. The taxpayer brought this action to obtain aa judgment declaring the invalidity of the back-assessment. The trial court ruled against the taxpayer. The Second District reversed, concluding that the property had not "escaped taxation," which is a prerequisite for a property appraiser's authority to assess back taxes under Fla. Stat. 193.092(1). The Supreme Court affirmed, holding that section 193.092(1) did not give the property appraiser authority to back-assess the taxpayer's property. View "Furst v. DeFrances" on Justia Law

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