Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of first-degree felony murder, robbery with a firearm, aggravated assault with a firearm, and burglary of a dwelling with an assault or battery while armed with a firearm and Defendant's sentence of death, holding that Defendant was not entitled to reversal on any of his allegations of error.Specifically, the Supreme Court held (1) the trial court did not err in finding that the State did not commit a discovery violation regarding a certain photograph; (2) the trial court did not err in admitting two photographs over an objection for lack of proper predicate and prejudicial impact; (3) the trial court did not abuse its discretion in denying Defendant's motions for mistrial; (4) the trial court did not err in allowing the State to argue during the penalty phase that Defendant possessed and discharged a firearm; (5) the penalty phase closing arguments did not violate Defendant's constitutional rights; (6) the penalty phase jury instructions and verdict form were proper; (7) the trial court’s sentencing order was legally deficient and incorrect as a matter of law; (8) there was sufficient evidence to sustain the conviction; and (9) Defendant's death sentence was proportionate. View "Smiley v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree murder and burglary of a dwelling with an assault and while armed with a firearm and Defendant's sentence of death, holding that this Court now joins federal courts and the majority of state courts in abandoning a special appellate standard to evaluate evidence on appeal in a wholly circumstantial case rather than in a case with some direct evidence.Defendant's convictions in this case were wholly based upon circumstantial evidence. The Supreme Court affirmed the convictions and sentence after discontinuing the use of the special standard of review previously applied to wholly circumstantial cases, holding (1) the standard of review now to be used in all cases where the sufficiency of the evidence is analyzed is whether the State presented competent, substantial evidence to support the verdict; (2) in this case, a rational trier of fact could have found the existence of the elements of the crime beyond a reasonable doubt; and (3) Defendant was not entitled to reversal of his convictions on any of his remaining allegations of error. View "Bush v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's claim of intellectual disability, raised in successive motions for postconviction relief under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in denying relief.Appellant was convicted of first-degree murder and sentenced to death in two separate cases. After the United States Supreme Court decided Hall v. Florida, 572 U.S. 701 (2014), Appellant filed successive motions for postconviction relief in both of his capital cases, asserting that the circuit court's denials of his previous claims of intellectual disability were based on the court's improper interpretation of Florida's intellectual disability statute. The circuit court summarily denied the motions. The Supreme Court reversed and remanded for an evidentiary hearing on the issue of intellectual disability. After a hearing, the circuit court denied the claim. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Appellant's intellectual disability claim; and (2) Appellant was not entitled to relief under Hurst v. Florida, 136 S. Ct. 616 (2016), or Hurst v. State, 202 So. 3d 40 (Fla. 2016). View "Franqui v. State" on Justia Law

The Supreme Court denied the instant mandamus petition filed by Hicks and sanctioned Hicks by barring him from filing any further pro se requests for relief related to his criminal case.Hicks was convicted of one count of lewd and lascivious conduct by a person over eighteen years of age on a victim under sixteen years of age. Since 2016, Hicks filed thirteen pro se requests for relief in the Supreme Court related to his criminal case. The Court did not grant the relief sought in any of Hicks' filings. In the instant petition, Hicks sought a writ of mandamus compelling the circuit court to comply with the requirements of Fla. R. Crim. P. 3.850 by filing a copy of an order denying his second postconviction motion with the clerk of court. The Supreme Court dismissed the petition and found that Hicks abused this Court's limited judicial resources. The Court directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Hicks that are related to his criminal case, unless such filings are signed by a member of The Florida Bar in good standing. View "Hicks v. State" on Justia Law

The Supreme Court held that Jay Barringer's quo warranto petition filed in this case was a frivolous proceeding brought before the Supreme Court by a state prisoner and sanctioned Barringer by barring him from filing any further pro se requests for relief related to his criminal case.Barringer was convicted of one count of attempted sexual battery of a victim less than twelve years old and sentenced to twenty-five-years' imprisonment. In 2011, Barringer began filing petitions in the Supreme Court. The Court did not grant the relief sought in any of Barringer's filings. In the instant quo warranto petition Barringer challenged his conviction on the ground that the information was defective, a claim Barringer previously raised by way of a habeas petition. The Supreme Court denied the petition and found that Barringer abused the Court's limited judicial resources. The Court sanctioned Barringer by directing the Clerk of Court to reject any future pleadings or other requests for relief submitted by Barringer that are related to his criminal case, unless such filings are signed by a member of The Florida Bar in good standing. View "Barringer v. Halkitis" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's successive motion to vacate his sentence of death under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in denying the Rule 3.851 motion.Appellant was convicted of first-degree murder, armed robbery, and grand theft. Appellant was sentenced to death for the murder. The Supreme Court affirmed the convictions but reversed Appellant's death sentence and remanded the case for a new penalty phase. After a new penalty phase, Appellant was again sentenced to death. In his successive Rule 3.851 motion, Appellant raised three claims. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court (1) properly denied Appellant's claim that his death sentence violated the Sixth and Eighth Amendments in light of Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016); (2) correctly denied Appellant's claim that his sentence violated the Eighth Amendment; and (3) did not err in denying Appellant's claim of newly discovered evidence. View "Archer v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's successive postconviction motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to postconviction relief.In 1993, Appellant's two death sentences became final. In his postconviction motion Appellant raised claims predicated on the United States Supreme Court's decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and the Supreme Court's decision on remand in Hurst v. State, 202 So. 3d 40 (Fla. 2016). The circuit court denied the motion. The Supreme Court affirmed, holding that this Court's precedent and the United States Supreme Court's precedent foreclosed relief as to Appellant's claims. View "Ponticelli v. State" on Justia Law

The Supreme Court affirmed Defendant's death sentences that were imposed after a second penalty phase, holding that there was no error or abuse of discretion.Defendant was convicted of two counts of first-degree murder and sentenced to death for each murder. The trial court granted a new penalty phase during postconviction proceedings on the grounds that counsel rendered ineffective assistance. After a second penalty phase, a death sentence was again imposed for each murder. The Supreme Court affirmed, holding (1) the trial court did not err by failing to instruct the jury that it must determine beyond a reasonable doubt whether the aggravators were sufficient to impose death and outweighed the mitigators; (2) none of the prosecutor's allegedly improper comments during closing argument rose to the level of fundamental error; (3) competent, substantial evidence supported the finding of the especially heinous, atrocious, or cruel aggravator; (4) the trial court did not abuse its discretion in rejecting two statutory mitigating circumstances presented with respect to both errors; and (5) the sentences of death were proportionate. View "Bright v. State" on Justia Law

The Supreme Court reviewed the findings, conclusions, and recommendations of the Judicial Qualifications Commission (JQC) concerning five judges (Respondents) and approved the stipulated discipline entered into between Respondents and the JQC, holding that the JQC's findings were supported by clear and convincing evidence.The JQC Investigative Panel served a notice of formal charges on Respondents for violating Canons 1, 2, and 4 of the Florida Code of Judicial Conduct. Thereafter, the JQC and Respondents entered into a stipulation wherein Respondents admitted their wrongdoing and agreed that the alleged violations were demonstrated by clear and convincing evidence. The parties further stipulated to the recommended discipline in the form of a written public reprimand. The Supreme Court agreed with the JQC's findings of fact approved the stipulated discipline of a written reprimand. View "Inquiry Concerning a Judge No. 18-572" on Justia Law

The Supreme Court approved for placement on the ballot an initiative petition to amend the Florida Constitution titled "All Voters Vote in Primary Elections for State Legislature, Governor, and Cabinet," holding that the Initiative complies with the single-subject requirement of Fla. Const. art. XI, 3 and that the ballot title and summary comply with the requirements of Fla. Stat. 101.161(1).Specifically, the Court held (1) the Initiative does not substantially alter or perform the functions of multiple branches of government and therefore complies with the single-subject requirement of article XI, section 3; and (2) the ballot title and summary comply with the requirements of section 101.161(1). View "Advisory Opinion to Attorney General Re All Voters Vote in Primary Elections for State Legislature, Governor & Cabinet" on Justia Law