Justia Florida Supreme Court Opinion Summaries

The Supreme Court approved a stipulation of the Judicial Qualifications Commission and Twentieth Judicial Circuit Court Judge Scott Cupp agreeing to the discipline of a public reprimand, holding that a public reprimand was appropriate.In the stipulation, Judge Cupp admitted to violating Canons of Judicial Conduct 1, 2B, and 7B(1)(b) and damaged the integrity of the judiciary by creating the appliance that he was interceding in a judicial election. Judge Cupp also admitted to violating Canon 7 and Fla. Stat. Chapter 106 during his 2020 reelection campaign and that his conduct damaged the public's perception of the judiciary. The Supreme Court approved the stipulation and ordered Judge Cupp to appear before the Supreme Court for the administration of a public reprimand. View "In re Judge Scott Cupp" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's second and third amended motions to vacate judgment and sentence, holding that the circuit court did not err.Defendant was convicted of one count of first-degree murder and one count of armed robbery. Defendant was sentenced to death for the murder. During voir dire, one potential juror, juror Smith, remained silent when asked about prior arrests when, in actuality, the juror had been adjudicated delinquent for sexual battery as a minor. In his postconviction motions, Defendant alleged that juror Smith's misconduct provided a basis for postconviction relief. The trial court denied relief. The Supreme Court affirmed, holding that Defendant's factual allegations, taken as true, would not demonstrate error on the part of trial counsel. View "Martin v. State" on Justia Law

The Supreme Court affirmed the sentence of death imposed on Defendant after a new penalty phase ordered by the Supreme Court, holding that there was no error in the proceedings below.Defendant was convicted of first-degree murder. The trial court sentenced Defendant to death. The Supreme Court remanded for a new penalty phase pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016), after, after a new penalty phase, the jury returned a unanimous verdict recommending that Defendant be sentenced to death. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding that Defendant failed to show error, much less prejudicial error. View "Deviney v. State" on Justia Law

In this certified conflict case, the Supreme Court held that a final judgment that modifies a preexisting parenting plan does not need to give a parent "concrete steps" to restore lost time-sharing and return to the premodification status quo.The parties in this case, the unmarried parents of a minor child, entered into a paternity agreement and parenting plan that was incorporated in a final judgment. Father later filed a petition to modify the parties' original parenting plan. The court entered a final judgment modifying the parenting plan. Mother appealed, arguing that the lower court's order was legally flawed because it lacked "concrete steps" that Mother could work toward to regain her lost timesharing. The court of appeal affirmed. The Supreme Court approved the decision below, holding that Mother's arguments in favor of a concrete steps requirement failed. View "C.N. v. I.G.C." on Justia Law

The Supreme Court struck a proposed amendment that would add a new section to Fla. Const. art. X, 33, holding that the language in the ballot summary indicating that the proposed qualifiedly "[p]ermits" the use and distribution of recreational marijuana was affirmatively misleading.The Attorney General petitioned the Supreme Court for an advisory opinion regarding the validity of an initiative petition titled "Adult Use of Marijuana." At issue was whether the proposed amendment complied with the single-subject requirement of Fla. Const. art. XI, 3 and whether the ballot title and summary complied with the clarity requirements of Fla. Stat. 101.161(1). The Supreme Court struck the proposed amendment, holding that the initiative petition was clearly and conclusively defective on the ground that the ballot summary failed to comply with Fla. Stat. 101.161. View "Advisory Opinion to Attorney General Re: Adult Use of Marijuana" on Justia Law

The Supreme Court affirmed Defendant's convictions of first-degree murder, sexual battery of a person under twelve years old, and kidnapping, and the imposition of the death penalty, holding that there was no prejudicial error in this case.Specifically, the Supreme Court held (1) the trial court did not commit fundamental error in failing to grant Defendant's motion for change of venue; (2) the trial court did not abuse its discretion in denying Defendant's motion for a mistrial on account of the interruption to the testimony of the state's expert; (3) the trial court did not abuse its discretion in denying Defendant's motion to exclude autopsy photographs during certain testimony; (4) Defendant was not entitled to relief on his claim that the state made inappropriate comments in its opening statement and in closing argument; and (5) there was no cumulative error in this case. View "Smith v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and his sentence of death, holding that Defendant failed to demonstrate any reversible error.Defendant pleaded guilty to first-degree murder and was sentenced to death. Defendant appealed, raising ten allegations of error. The Supreme Court affirmed, holding (1) the trial court did not err in allowing Defendant to represent himself during trial; (2) the trial court did not err in accepting Defendant's guilty plea; (3) the trial properly renewed the offer of counsel at all critical stages of the proceedings; (4) there was no reversible error in the trial court's findings on the statutory aggravators alleged by the State and on certain statutory and non statutory mitigators; (5) any error in the trial court's inclusion of a sentencing recommendation in the presentence investigation report did not rise to the level of fundamental error; and (6) Defendant was not entitled to relief on his remaining allegations of error. View "Woodbury v. State" on Justia Law

The Supreme Court affirmed the judgment of the postconviction court denying Appellant's initial postconviction motion filed under Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief on his allegations of error.Appellant was convicted of two counts of first-degree premeditated murder and one count of escape while being transported. The trial court sentenced Appellant to death. Appellant later filed a postconviction motion raising seven claims. The circuit court granted an evidentiary hearing on most of Appellant's claims and then denied the postconviction motion as to all claims. The Supreme Court affirmed, holding that the postconviction court did not err in denying Appellant's claims of newly discovered evidence, ineffective assistance of counsel, cumulative error, and a Brady violation. View "Morris v. State" on Justia Law

The Supreme Court approved the decision of the First District Court of Appeal dismissing Defendant's appeal of the denial of his motion filed under Fla. R. Crim. P. 3.800(a), holding that Defendant could not show that the denial of his rule 3.800(a) motion was in error.Defendant was convicted of armed robbery of a firearm and kidnapping to facilitate a felony and sentenced to concurrent life sentences for both counts. In his rule 3.800(a) motion, Defendant argued that his life sentences were illegal because the trial court failed to impose ten-year mandatory minimum sentences pursuant to Fla. Stat. 775.087(2). The postconviction court denied the motion, concluding that the sentencing judge's failure to impose the ten-year mandatory minimum sentences did not render Defendant's sentences illegal because he did not benefit from the error. The court of appeals affirmed. The Supreme Court affirmed, holding that Defendant could not show that the denial of his rule 3.800(a) motion resulted in harm that may be remedied on appeal. View "Earl v. State" on Justia Law

The Supreme Court answered in the affirmative a question certified to it by the Fifth District Court of Appeals and quashed the Fifth District's decision in this case, holding that the lowest permissible sentence as defined by Fla. Stat. 921.0024(2) is an individual minimum sentence and not a collective minimum sentence where there are multiple convictions subject to sentencing on a single scoresheet.Defendant was convicted of attempted first-degree murder and other crimes. The Fifth District reversed the attempted first-degree murder, and Defendant was resentenced for his remaining conviction. The Criminal Punishment Code Scoresheet indicated that the lowest permissible sentence (LPS) was 107.25 months. The trial court concluded that the LPS is an individual minimum sentence that must be applied to each offense if the LPS exceeds each individual statutory maximum sentence. The Fifth District reversed, ruling that the LPS is an individual minimum sentence that applies to each offense even though the LPS did not exceed the statutory maximum sentence for the primary offense. The Supreme Court quashed the Fifth District's decision, holding that the LPS is an individual minimum sentence that must be imposed when the LPS exceeds the statutory maximum sentence for each offense. View "State v. Gabriel" on Justia Law