Justia Florida Supreme Court Opinion Summaries

The Supreme Court held that a defendant's potential designation as a prison releasee reoffender (PRR) under Fla. Stat. 775.082(9)(a)1. is not a sufficient collateral legal consequence to preclude dismissal of an appeal challenging a state prison sentence erroneously imposed pursuant to a trial court's dangerousness finding under section 775.082(1).The decision of the Fourth District Court of Appeal in this case expressly and directly conflicted with that of the First District Court of Appeal in Johnson v. State, 260 So. 3d 502 (Fla. 1st DCA 2018). The district courts reached separate conclusions as to whether a defendant's potential designation as a prison releasee reoffender is a sufficient collateral legal consequence precluding dismissal of such an appeal. The Supreme Court approved the Fourth District's decision and disapproved the First District's decision, holding that a defendant's potential PRR designation under section 775.082(9)(a)1. is not a sufficient collateral legal consequence flowing from a state prison sentence erroneously imposed pursuant to a trial court's dangerousness finding to preclude dismissal of an appeal as moot where the defendant has served the incarcerate portion of the sentence. View "Casiano v. State" on Justia Law

The Supreme Court answered in the negative a question certified by the Fifth District Court of Appeal, holding that in a first-party breach of insurance contract action brought by an insured against its insurer not involving suit under Fla. Stat. 624.155, Florida law does not allow the insured to recover extra-contractual, consequential damages.The insureds in this case sought to recover from the insurer extra-contractual, consequential damages for lost rental income. The trial court granted the insurer's motion for partial summary judgment regarding the breach of contract claim for lost rental income. The Fifth District reversed the partial summary judgment regarding the consequential damages claim, concluding that the insurer was not statutorily immune from this aspect of the insureds' claim. The Supreme Court quashed the Fifth District's decision and remanded the case, concluding that extra-contractual, consequential damages are not available in a first-party breach of insurance contract action. View "Citizens Property Insurance Corp. v. Manor House, LLC" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's successive post conviction motion file pursuant to Fla. R. Crim. P. 3.851, holding that Appellant's claims failed.In 1983, Appellant was convicted of first-degree murder, sexual battery, burglary of a dwelling, and second-degree grand theft. Appellant was sentenced to death. Following the denial of his first three postconviction motions Appellant filed a third successive postconviction motion raising claims based on the retroactivity of Hurst v. Florida, 577 U.S. 92 (2016). The trial court denied relief. The Supreme Court affirmed, holding that the trial court did not err in denying Appellant's motion. View "Wright v. State" on Justia Law

The Supreme Court held that there should not be an exception to the present summary judgment standards applied by Florida state courts that would allow for summary judgment in favor of the moving party when the movant's video evidence negates or refutes any conflicting evidence presented in opposition to the summary judgment motion and there is no evidence that the videotape evidence has been altered or doctored.In this case arising from a fatal rear-end car crash the trial court granted summary judgment for Defendants, relying on video evidence from the front car's forward-facing dashboard camera that appeared to refute Plaintiff's version of the events. The Fifth District Court of Appeal reversed, concluding that the trial court improperly weighed competing evidence on material facts. The Supreme Court approved the result, holding that there was no reason to adopt an ad hoc video evidence exception to the existing summary judgment standard. View "Wilsonart, LLC v. Lopez" on Justia Law

The Supreme Court imposed sanctions upon Defendant, holding that, based on his persistent history of filing pro se petitions that were meritless or otherwise inappropriate for the Supreme Court's review, Defendant abused the judicial process and burdened the Court's limited judicial resources.This case was before the Supreme Court on Defendant's petition for a writ of mandamus. The Supreme Court denied the petition and, concurrently with the denial, expressly retained jurisdiction to pursue possible sanctions. The Court directed Defendant to show cause why he should not be barred from filing any further requests for relief. The Court held that Defendant's response failed to show cause why sanctions should not be imposed. View "Jackson v. State" on Justia Law

The Supreme Court concluded that a unilateral attorney's fee provision in a note and mortgage was made reciprocal to a borrower under Fla. Stat. 57.105(7) where the borrower prevailed in a foreclosure action in which the plaintiff bank established standing to enforce the note and mortgage at the time of trial but not at the time suit was filed, holding that the statutory conditions were met.The Fourth District Court of Appeal held that a borrower who successfully argues that the bank lacked standing at the time suit was filed could not rely on the contract to obtain attorney's fees under section 57.105(7). The Supreme Court reversed, holding that the borrowers were eligible to recover reciprocal fees under the statute because the conditions in the statute's two clauses were satisfied here. View "Page v. Deutsche Bank Trust Company Americas" on Justia Law

The Supreme Court held that a unilateral attorney's fee provision in a credit card contract was made reciprocal to prevailing debtors under Fla. Stat. 57.105(7) where the debtors prevailed in an account stated action brought to collect unpaid credit card debt.The First District Court of Appeal held that the debtors could not recover attorney's fees on the grounds that section 57.105(7) was inapplicable because the actions for account stated did not rely upon the credit card contracts containing the fee provisions. The Supreme Court quashed the decision below, holding that section 57.105(7) allowed the debtors to recover reciprocal attorney's fees because the conditions required by the statute were met. View "Ham v. Portfolio Recovery Associates, LLC" on Justia Law

The Supreme Court quashed the decision of the Second District Court of Appeal concluding that Defendant's dual convictions for driving under the influence (DUI) with serious bodily injury and driving while license suspended (DWLS) with serious bodily injury as to the same victim were prohibited, holding that Defendant's dual convictions were not prohibited.Relying on its decision in Kelly v. State, 987 So. 2d (Fla. 2d DCA 2008), the Second District concluded that Defendant's convictions violated the single homicide rule. The Supreme Court disagreed, holding (1) the appropriate analysis for whether dual convictions for DUI with serious bodily injury and DWLS with serious bodily injury are prohibited under the constitutional protection against double jeopardy is the same-elements test in Fla. Stat. 775.021; and (2) therefore, dual convictions for these offenses do not violate the constitutional prohibition against double jeopardy. View "State v. Marsh" on Justia Law

The Supreme Court answered in the negative a certified question asking whether the single homicide rule found in House v. State, 474 So. 2d 1193 (Fla. 1985), precludes separate convictions of vehicular homicide and fleeing and eluding causing serious injury or death that involve the same victim.Defendant stabbed his girlfriend and ran over her with a car, resulting in her death. During a high-speed chase with law enforcement officers after fleeing the scene, Defendant crashed into another vehicle, killing two passengers. Defendant was convicted of one count of first-degree murder with a weapon, three counts of fleeing or attempting to elude a law enforcement officer causing serious injury or death, and two counts of vehicular homicide. On appeal from the denial of Defendant's postconviction motion, the Fifth District Court of Appeals concluded that Defendant's convictions were prohibited under the single homicide rule. The Supreme Court quashed the Fifth District's decision, holding that Defendant's dual convictions for vehicular manslaughter and fleeing or eluding causing serious injury or death are not prohibited under the same-elements test codified in Fla. Stat. 775.021(4). View "State v. Maisonet-Maldonado" on Justia Law

The Supreme Court affirmed Defendant's two sentences of death imposed during a resentencing that the Supreme Court ordered as a result of a Hurst v. State, 202 So. 3d 40 (Fla. 2016), error, holding that Defendant was not entitled to relief on his claims.Defendant was convicted of two counts of first-degree murder and other crimes and sentenced by a jury to death. The Supreme Court affirmed. Defendant later filed a motion for postconviction relief, which the circuit court denied. The Supreme Court vacated Defendant's death sentences due to Hurst error. At the conclusion of a new penalty phase trial, the resentencing jury voted to recommend that Defendant be sentenced to death for both of his murder convictions. The trial court followed the resentencing jury's recommendation and sentenced Defendant to death as to both counts. The Supreme Court affirmed, holding (1) even assumed that the trial court erred by limiting the scope of voir dire by restricting Defendant's use of a hypothetical question, any error was harmless; and (2) the trial court's other rulings with respect to voir dire were not improper. View "Hojan v. State" on Justia Law