Justia Florida Supreme Court Opinion Summaries

The Supreme Court denied the State's petition seeking an extraordinary writ that would direct the circuit court to dismiss a resentencing proceeding and reinstate two previously vacated death sentences for the State or, alternatively, a writ of prohibition that would bar the circuit court from conducting the resentencing, holding that Defendant's vacated death sentences cannot be retroactively reinstated.In 2017, Defendant filed a successive postconviction motion seeking relief under Hurst v. State, 202 So. 3d 40 (Fla. 2016). The postconviction court granted Defendant a new penalty phase, scheduled to begin in 2020, and the State did not appeal the order granting relief. Before trial, the State filed a motion requesting that the circuit court dismiss the resentencing proceeding and maintain Defendant's sentences of death, seeking to apply the holding in State v. Poole, 297 So. 3d 487 (Fla. 2020), to Defendant's case. The circuit court denied the motion. Thereafter, the State filed its emergency all writs petition and petition for writ of prohibition. The Supreme Court denied relief, holding that a death sentence that was vacated by the postconviction court cannot be "reinstated" if the State never appealed the final order granting relief, the resentencing has not yet taken place, and the Supreme Court has since receded from the decisional law on which the sentence was vacated. View "State v. Jackson" on Justia Law

The Supreme Court held that its 2017 judgment vacating on direct appeal Defendant's death sentence is final, that neither the Supreme Court nor the trial court can lawfully reinstate that sentence, and that, therefore, resentencing was required.In 2015, Defendant was sentenced to death for first-degree premeditated murder. In 2017, relying on the then-applicable rule of Hurst v. State, 202 So. 3d 40 (Fla. 2016), the Supreme Court vacated Defendant's death sentence and remanded for a new penalty phase proceeding. In 2020, the Supreme Court decided State v. Poole, 297 So. 3d 487 (Fla. 2020), in which the Court receded from Hurst. Because Defendant would have been constitutionality eligible for a death sentence under the rule of Poole the State asked the trial court to reinstate Defendant's death sentence. The trial court denied the State's motion. Thereafter, the State filed a petition arguing that reinstatement of Defendant's death sentence was required under Poole. The Supreme Court denied the petition, holding that the Court cannot reconsider its judgment vacating Defendant's death sentence and that the trial court also lacked the authority to reconsider the Supreme Court's final judgment vacating Defendant's death sentence. View "State v. Okafor" on Justia Law

The Supreme Court affirmed Defendant's two first-degree murder convictions and two corresponding sentences of death, holding that Defendant's assignments of error were unavailing.Specifically, the Supreme Court held (1) the trial court did not err in instructing on and finding the CCP aggravator and the HAC aggravator; (2) the trial court did not err in instructing on and finding the HAC aggravator; (3) Florida’s death penalty statute is constitutional; (4) the trial court did not abuse its discretion in rejecting Defendant's two proposed impairment mitigators; (5) the trial court did not err in allowing victim impact evidence; (6) the prosecutor’s penalty phase closing argument did not violate Defendant's constitutional rights; and (7) competent, substantial evidence supported Defendant's first-degree murder convictions. View "Colley v. State" on Justia Law

The Supreme Court affirmed Defendant's first-degree murder conviction and sentence of death, holding that any error in the proceedings below was not prejudicial.Defendant pleaded guilty to the first-degree murder of his cellmate. The trial court accepted the plea, finding that it was freely, voluntarily, knowingly and intelligently given. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding (1) the trial court erred in one aspect of how it handled mitigation, but the error did not prejudice Defendant; (2) the trial court did not fundamentally error by failing to determine beyond a reasonable doubt that the aggravating factors were sufficient to justify the death penalty; (3) the trial court’s failure to enter a written order finding Defendant competent to proceed after orally announcing its competency finding did not constitute fundamental error; and (4) Defendant's guilty plea was knowingly, intelligently, and voluntarily entered. View "Craft v. State" on Justia Law

The Supreme Court held that the conduct of Judge David Craig Miller of the Eleventh Judicial Court violated the Code of Judicial Conduct and that the appropriate discipline was a public reprimand, concluding that the findings of the Judicial Qualifications Commission (JQC) were supported by clear and convincing evidence.In its findings and recommendation of discipline, the JQC found that Judge Miller violated Canons 1, 2A, and 3B(4) of the Code of Judicial Conduct. The JQC then recommended a public reprimand. In a stipulation, Judge Miller admitted to the alleged conduct, conceded that the conducts violated the Code of Judicial Conduct, and accepted the JQC's findings and recommendation of discipline. The Supreme Court approved the stipulation entered into by Judge Miller and the JQC and reprimanded Judge Miller for his misconduct. View "Inquiry Concerning Judge David Craig Miller" on Justia Law

The Supreme Court held that the conformity clause of Fla. Const. art. I, 17 precluded the Court from analyzing death sentences for comparative proportionality in the absence of a statute establishing that review.Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant's sentence of death. The trial court later vacated Defendant's death sentence and ordered a new penalty phase proceeding pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016). The trial court subsequently sentenced Defendant to death. On appeal, Defendant argued that his death sentence was disproportionate in comparison to other cases in which the Court upheld the imposition of the death penalty. The State urged the Court to recede from precedent holding that the Court must review the comparative proportionality of every death sentence because comparative proportionality review violates the conformity clause. The Supreme Court agreed, holding that the conformity clause expressly forecloses this court's imposition of a comparative proportionality review requirement that is predicated on the Eighth Amendment. View "Lawrence v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree murder and his sentence of death, holding that no error occurred in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion in denying Defendant's request for self-representation as equivocal; (2) the trial court did not abuse its discretion in denying Defendant's peremptory challenge to an African American juror; (3) the trial court did not err in instructing the penalty phase jury; (4) the trial court did not abuse its discretion by admitting statements made by Defendant's prior victim in support of the prior violent felony aggravator; (5) competent, substantial evidence supported the trial court's finding of the HAC aggravator and the CCP aggravator; (6) Craven’s death sentence was proportionate; and (7) the evidence was sufficient to support Defendant's conviction for first-degree murder. View "Craven v. State" on Justia Law

In this child sexual abuse case concerning the separation of powers and the proper role of courts in applying statutes of limitations the Supreme Court held that courts cannot go beyond the statutory framework and adopt a special, judge-made rule to govern the accrual of tort claims where the would-be plaintiff is a minor.Petitioners alleged that Daniel Heffield sexually abused them as children. Petitioners filed the underlying lawsuit against New Life Community Church, Daniel's employer at the time of the alleged abuse, and other defendants, alleging negligence claims and a respondeat superior claim. Respondents (other than Daniel) moved for summary judgment, arguing that Petitioners' claims were untimely. The trial court entered summary judgment for Respondents, concluding that Petitioners' claims accrued at the time of injury and therefore were untimely. The court of appeal affirmed. On appeal, Petitioners argued that the accrual of their claims were governed by the judge-made delayed accrual rule that the Supreme Court applied in Hearndon v. Graham, 767 So. 2d 1179 (Fla. 2000). The Supreme Court affirmed, holding (1) the statutory framework leaves no room for supplemental common law accrual rules; and (2) the Hearndon decision did not apply to delay the accrual of Petitioners' claims. View "R.R. v. New Life Community Church of CMA, Inc." on Justia Law

The Supreme Court answered a certified question by holding that a mass shooting committed by Patrick Dell was a single "incident or occurrence" for purposes of Fla. Stat. 768.28(5) and that the cumulative liability for all claims of injury resulting from the incident may not exceed the aggregate cap of $200,000 set forth in section 768.28(5).Dell fatally shot his former wife and four of her children and severely wounded a fifth child. Plaintiffs, the two fathers of the deceased and injured children, sued the Florida Department of Children and Families (DCF) alleging wrongful death and negligence. The trial court granted partial summary judgment for Plaintiffs and determined that each wrongful death or personal injury claim was eligible for the $100,000 per person and $200,000 per claim limitation found in section 768.28(5). The court of appeal reversed, concluding that the claims arose from the same incident of negligence, and therefore, the $200,000 cap per incident or occurrence applied to limit recovery for all claims. The Supreme Court approved of the court of appeal's result, holding that the claims stemming from the mass shooting of Dell's victims were subject to the $200,000 aggregate cap for damages paid by the State, its agencies, or subdivisions. View "Barnett v. State, Department of Financial Services" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Defendant's successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the circuit court properly denied relief.Defendant was found guilty of first-degree murder and was sentenced to death. In his successive postconviction motion, Defendant claimed that he was entitled to relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016), and that the indictment was defective because it failed to include aggravating factors. The circuit court denied relief. The Supreme Court affirmed, holding (1) this Court's decision in State v. Poole, 297 So. 3d 487 (Fla. 2020), foreclosed relief on Defendant's Hurst claims; and (2) Defendant's claim that the indictment was defective was procedurally barred. View "Lott v. State" on Justia Law