Justia Florida Supreme Court Opinion Summaries

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

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