Justia Florida Supreme Court Opinion Summaries

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

The Supreme Court affirmed the order of the trial court denying Appellant's successive postconviction motion filed pursuant to Fla. R. Crim. P. 3.851 seeking relief from his sentence of death pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016), holding that State v. Poole, 45 Fla. L. Weekly S41 (Fla. Jan. 23, 2020), was dispositive in this case.Appellant's death sentence became final in 1990, before the Supreme Court decided Ring v. Arizona, 536 U.S. 584 (2002). The Supreme Court subsequently decided Poole, pursuant to which there was no Hurst error in Appellant's case because a unanimous jury finding establishes the existence of at least one statutory aggravating circumstance beyond a reasonable doubt. In the instant case, the Supreme Court held that two of the four statutory aggravating circumstances found by the trial court - that the capital felony was committed during the commission of a sexual battery and for pecuniary gain - were established because Appellant's jury found him guilty of the contemporaneous crimes of sexual battery and robbery. View "Reed v. State" on Justia Law

The Supreme Court affirmed the order of the trial court summarily denying Appellant's successive motion for post conviction relief pursuant to Fla. R. Crim. P. 3.851 and, alternatively, to correct an illegal sentence pursuant to Fla. R. Crim. P. 3.800(a), holding that there was no error in the trial court's summary denial of relief.In his postconviction relief motion, Appellant sought relief from his sentence of death, raising claims predicated on Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 S. 3d 40 (Fla. 2016). The trial court summarily denied relief. The Supreme Court affirmed, holding that Appellant's claims were procedurally barred, and even without the procedural bar, this Court's recent decision in State v. Poole, 45 Fla. L. Weekly S41 (Fla. Jan. 23, 2020), foreclosed relief. View "Boyd v. State" on Justia Law

The Supreme Court approved the court of appeal's decision to uphold Defendant's sentence and disapproved of several recent court decisions to the extent they held that resentencing is required for all juvenile offenders serving a sentence longer than twenty years without the opportunity for early release based on demonstrated maturity and rehabilitation, holding that Defendant in this case did not establish a violation of Miller v. Alabama, 567 U.S. 460 (2012).Defendant was charged with the first-degree murder of her mother committed when she was age seventeen. Defendant pled guilty to second-degree murder in exchange for a forty-year sentence. Defendant later challenged her sentence as cruel and unusual punishment under Miller. The trial court denied Defendant's petition. The court of appeal affirmed but certified conflict with several decisions of other district courts. The Supreme Court affirmed, holding that because Defendant did not establish that her sentence was a life sentence or the functional equivalent of a life sentence Defendant failed to establish that her sentence violated the Eighth Amendment, Miller, or its equivalent on a juvenile homicide offender whose youth has not been taken into account at sentencing. View "Pedroza v. State" on Justia Law