Justia Florida Supreme Court Opinion Summaries

In April 2011, JJJTB, Inc. initiated a foreclosure action against Stephen Schmidt and Schmidt Farms, Inc. in Hillsborough County. In 2015, the Thirteenth Judicial Circuit denied the foreclosure judgment, and the Second District Court of Appeal affirmed this decision. Over two years later, JJJTB amended its complaint to include new defaults. Schmidt moved to dismiss the amended complaint but did not argue lack of case jurisdiction. The trial court denied the motion, and Schmidt filed an answer with affirmative defenses and a counterclaim but again did not raise the issue of case jurisdiction. In 2021, the court entered a foreclosure judgment against Schmidt, who then unsuccessfully moved for rehearing, asserting lack of subject matter jurisdiction.Schmidt appealed to the Second District Court of Appeal, arguing the trial court lacked jurisdiction. The Second District reversed the foreclosure judgment, holding that the trial court lacked case jurisdiction and that such objections cannot be waived. The court certified conflict with the Fourth District Court of Appeal's decision in MCR Funding v. CMG Funding Corp., which held that case jurisdiction is waivable.The Supreme Court of Florida reviewed the case to resolve the conflict. The court held that case jurisdiction is waivable and that objections must be timely raised, or they are waived. The court quashed the Second District's decision and approved the Fourth District's decision in MCR Funding. The Supreme Court concluded that Schmidt waived the objection to the trial court's lack of case jurisdiction by not raising it timely and by seeking affirmative relief. The Second District erred in reversing the foreclosure judgment based on untimely objections to case jurisdiction. View "JJJTB, Inc. v. Schmidt" on Justia Law

Anthony Rojas, a student at the University of Florida, filed a class action lawsuit against the University of Florida Board of Trustees. Rojas claimed that the University breached its contract by suspending on-campus services and closing facilities during the COVID-19 pandemic, despite students being required to pay mandatory fees for these services. He also alleged that the University failed to refund these fees. The complaint included a spring 2020 tuition statement, a general statement of tuition and fee estimates for the 2019-2020 academic year, and the University’s financial liability agreement.The trial court dismissed the unjust enrichment claim but denied the University’s motion to dismiss the breach of contract claim, ruling that the complaint adequately pleaded the existence of an express contract. The University appealed, and the First District Court of Appeal reversed the trial court’s decision, holding that the claims were barred by sovereign immunity. The First District concluded that the contract alleged by Rojas did not constitute an express written contract sufficient to overcome sovereign immunity.The Supreme Court of Florida reviewed the case and quashed the First District’s decision. The Court held that the waiver-by-contract doctrine does not preclude claims based on the breach of implied covenants or conditions that do not conflict with express contract provisions. The Court found that the First District erred in requiring extraordinary specificity in government contracts and in failing to recognize permissible implied covenants. The case was remanded for further proceedings consistent with this opinion. View "Rojas v. University of Florida Board of Trustees" on Justia Law

In 2009, Timothy W. Fletcher was convicted of first-degree murder for the death of Helen Googe. Fletcher and his cellmate, Doni Ray Brown, escaped from jail and went to Googe’s home to steal money. Fletcher confessed to his involvement, although he initially claimed Brown was the primary aggressor. The physical evidence, including DNA under Googe’s fingernails, linked Fletcher to the crime. The jury found Fletcher guilty and recommended the death penalty by a vote of eight to four.Fletcher’s initial death sentence was vacated due to a non-unanimous jury recommendation, and he was granted a new penalty phase under Hurst v. State. During the new penalty phase, the State presented evidence to support four aggravating factors, while Fletcher presented evidence of forty-nine mitigating circumstances. The jury unanimously found all four aggravating factors and recommended the death penalty. The trial court merged two aggravators and found three aggravating factors, giving them great weight, and considered fifty-two mitigating factors, giving moderate weight to the cumulative mitigation.Fletcher appealed to the Supreme Court of Florida, raising nine issues, including claims of prosecutorial misconduct, jury nullification, and the constitutionality of Florida’s capital sentencing scheme. The court found no reversible error, concluding that the prosecutor’s comments did not improperly denigrate mitigating evidence, the jury followed instructions, and the victim impact evidence was admissible. The court also rejected Fletcher’s constitutional challenges to the death penalty statute and the aggravating factors applied in his case. The court affirmed Fletcher’s death sentence, finding that the trial court properly weighed the aggravating and mitigating factors and that the jury’s recommendation was supported by the evidence. View "Fletcher v. State of Florida" on Justia Law

Wilfred Ramos, Jr. was employed by Steak N Shake as a grill operator. After sustaining a back injury in a car accident, Ramos alleged that Steak N Shake reduced his work hours and eventually terminated him in retaliation for his disability and requests for accommodations. Ramos filed a charge of discrimination with the EEOC, marking "Retaliation" and "Disability" and citing the Americans with Disabilities Act of 1991. The charge was dual-filed with the Florida Commission on Human Relations but did not specifically reference the Florida Civil Rights Act (FCRA).The trial court granted summary judgment in favor of Steak N Shake, concluding that Ramos failed to exhaust his administrative remedies under the FCRA because he did not specifically allege FCRA claims in his charge of discrimination. The Second District Court of Appeal reversed this decision, holding that Ramos was not required to specifically allege FCRA claims in his charge of discrimination to exhaust administrative remedies. The Second District certified conflict with the Fourth District's decision in Belony v. North Broward Hospital District, which held that merely asserting a violation of federal law in a dual-filed charge was insufficient to satisfy the FCRA's requirements.The Supreme Court of Florida reviewed the case and held that a claimant does not need to specifically allege they are seeking relief under the FCRA to exhaust administrative remedies when dual-filing a charge of discrimination with the EEOC and the Florida Commission on Human Relations. The Court approved the Second District's decision and disapproved the Fourth District's decision in Belony to the extent it held otherwise. View "Steak N Shake, Inc. v. Ramos" on Justia Law

A woman’s nude body was discovered near the Vaca Cut Bridge in Marathon, Florida, with evidence of ligature strangulation and severe sexual injuries. Car parts found near the body matched damage to a conversion van driven by Steven Wolf, who was detained nearby. Wolf gave inconsistent statements to law enforcement, initially denying involvement but later admitting to being present when the victim died in his van and to disposing of evidence. Forensic evidence, including DNA, linked Wolf to the victim and the crime scene. The medical examiner determined the victim was alive during the infliction of fatal injuries, which could not have been caused by male genitalia, and that she suffered extreme pain before death.Wolf was charged in the Circuit Court with first-degree murder, two counts of sexual battery with force likely to cause injury, and tampering with physical evidence. He was found guilty on all counts by a jury. During the penalty phase, the State presented evidence of Wolf’s prior violent felony conviction. The jury unanimously found all aggravating factors proven and recommended a death sentence. The trial court agreed, finding the aggravating factors outweighed the mitigating circumstances and sentenced Wolf to death.On direct appeal, the Supreme Court of Florida reviewed Wolf’s claims, including challenges to venue, jury selection, evidentiary rulings, prosecutorial misconduct, jury instructions, and the sufficiency of the evidence. The court held that venue was properly established in Monroe County, the trial court did not abuse its discretion in jury selection or evidentiary rulings, and the improper prosecutorial comments did not rise to fundamental error. The court also found sufficient evidence supported the convictions and the especially heinous, atrocious, or cruel aggravator. The Supreme Court of Florida affirmed Wolf’s convictions and sentence of death. View "Wolf v. State of Florida" on Justia Law

The appellant was married to the victim, with whom he shared two daughters, and was also living with her two sons from a previous marriage. In July 2019, following an argument, he killed his wife by beating her with a baseball bat and concealed her body in their home. Over the following weeks, he lied to family and friends about her whereabouts, impersonating her in communications. As the children returned home before the start of school, he became concerned that the boys might reveal their mother’s absence. He then killed the two boys, one by strangulation and the other by drowning, and later killed his two daughters in a similar manner. He concealed all five bodies in storage boxes, eventually transporting them in a minivan. After a wellness check was requested by the victim’s family, law enforcement began investigating. The appellant fled the state, ultimately confessing to the murders after a car accident in Georgia, and led police to the children’s remains.A grand jury in Marion County, Florida, indicted the appellant on four counts of first-degree murder (for the children) and one count of second-degree murder (for his wife). He pleaded guilty to all charges. At the penalty phase, the State sought six aggravating factors for each first-degree murder count. The defense presented expert testimony regarding the appellant’s mental health, arguing for mitigation. The trial court denied a defense request for a special jury instruction on the “avoid arrest” aggravator, gave the standard instruction, and the jury recommended death sentences. The court imposed four death sentences, finding all aggravators proven and that they outweighed mitigation.The Supreme Court of Florida reviewed the case, affirming the convictions and sentences. The court held that the trial court did not abuse its discretion in denying the special jury instruction, found Florida’s capital sentencing scheme constitutional, and determined the appellant’s guilty plea was knowingly, intelligently, and voluntarily entered. The convictions and death sentences were affirmed. View "Jones v. State of Florida" on Justia Law

Michael Bernard Bell was convicted of the 1993 first-degree murders of Jimmy West and Tamecka Smith. Bell sought revenge for his brother's death and purchased an AK-47. He mistakenly identified West as his target and shot both West and Smith. Bell was sentenced to death, with the trial court finding three aggravating factors and one mitigating circumstance. The Florida Supreme Court affirmed his convictions and sentences on direct appeal, and the U.S. Supreme Court denied certiorari.Bell filed multiple postconviction relief motions. The circuit court denied his initial motion, but the Florida Supreme Court remanded for an evidentiary hearing, which ultimately resulted in a denial of relief. Subsequent motions were also denied, including claims related to retroactive application of legal decisions and ineffective assistance of counsel. Bell's federal habeas petitions were similarly unsuccessful.Governor Ron DeSantis signed Bell’s death warrant in June 2025, prompting Bell to file a successive motion for postconviction relief, raising claims of newly discovered evidence, Brady and Giglio violations, and racial bias. The circuit court granted an evidentiary hearing on the newly discovered evidence claim but ultimately denied relief.The Florida Supreme Court reviewed the case and affirmed the circuit court's denial of Bell’s successive postconviction motion. The court found that Bell's claims of newly discovered evidence, including alleged recantations and prosecutorial misconduct, were either untimely or lacked merit. The court also rejected Bell's arguments regarding the totality of circumstances and the timeframe of his death warrant. Consequently, the court denied Bell's motion for a stay of execution and his request for oral argument. View "Bell v. State of Florida" on Justia Law

Scottie D. Allen, a prisoner under a death sentence, appealed the circuit court's summary denial of his initial motion for postconviction relief under Florida Rule of Criminal Procedure 3.851 and the denial of his request for public records under Rule 3.852. Allen also petitioned for a writ of habeas corpus. Allen was convicted of first-degree premeditated murder for strangling his cellmate, Ryan Mason, at Wakulla Correctional Institution. Allen represented himself during the trial and penalty phases, where he confessed to the murder and declined to present any mitigation.The trial court found Allen competent to waive counsel and represent himself. The jury convicted Allen and recommended the death penalty, finding four aggravating factors. The trial court ordered a presentence investigation report (PSI) and appointed amicus counsel to present mitigation at the Spencer hearing. Despite Allen's objections, the trial court allowed the State's mental health expert to evaluate him. The trial court sentenced Allen to death, finding significant aggravating factors and some mitigating circumstances.On direct appeal, the Florida Supreme Court affirmed Allen's conviction and death sentence. Allen then filed a motion for postconviction relief, raising several claims, including issues with the PSI, the trial court's handling of mitigation, and his competency to represent himself. The circuit court summarily denied the motion, finding the claims procedurally barred or without merit.The Florida Supreme Court reviewed the case and affirmed the circuit court's denial of postconviction relief and the request for additional public records. The court found that Allen's claims were procedurally barred as they could have been raised on direct appeal and were without merit. The court also denied Allen's habeas petition, concluding that his appellate counsel was not ineffective for failing to raise meritless or unpreserved issues. View "Allen v. State of Florida" on Justia Law

The case involves Jourdan Parks, who was adjudicated guilty of five charges and sentenced to 25 years in prison as a habitual felony offender. The trial court also imposed a $100 cost for the state attorney as mandated by section 938.27(8) of the Florida Statutes, despite the State not expressly requesting it. Parks moved to correct this alleged sentencing error, arguing that subsection (1) of the same statute required a request by the State for such costs. The trial court rejected this argument, relying on the 2008 amendment to subsection (8) that mandates these costs.The First District Court of Appeal affirmed the trial court's decision, holding that the minimum cost for the state attorney is mandatory under subsection (8) and does not require a request by the State. This decision conflicted with the Second District Court of Appeal's ruling in D.L.J. v. State, which held that a request by the State was necessary for imposing such costs, based on subsection (1) of the statute.The Supreme Court of Florida reviewed the case to resolve the conflict between the First and Second District Courts of Appeal. The Court concluded that the specific mandate of subsection (8), which requires the imposition of minimum costs for the state attorney without a request by the State, controls over the general language of subsection (1). The Court approved the First District's decision in Parks and disapproved the Second District's decision in D.L.J., holding that the minimum costs for the state attorney must be imposed even in the absence of a request by the State. View "Parks v. State of Florida" on Justia Law

The case involves several taxicab companies in Hillsborough County, Florida, which held certificates and permits issued by the Hillsborough County Public Transportation Commission (PTC). The PTC was a special district created by the Legislature to regulate taxicabs. In 2012, a law declared these certificates and permits to be the private property of their holders, allowing them to be transferred or devised. However, in 2017, the Legislature repealed the 2012 law, dissolved the PTC, and returned regulatory authority to Hillsborough County, which chose not to recognize the PTC-issued certificates and permits.The taxicab companies filed a lawsuit claiming that the repeal of the 2012 law and the dissolution of the PTC constituted a taking of their property without compensation, violating the Florida Constitution’s Takings Clause. The trial court granted summary judgment in favor of Hillsborough County, concluding that the certificates and permits had effectively vanished when the PTC was dissolved. However, the court denied the State's motion to dismiss, allowing the possibility of claims for damages against the State.The Second District Court of Appeal affirmed the trial court's judgment in favor of Hillsborough County and reversed the denial of the State's motion to dismiss, holding that the taxicab companies did not have a property interest in the PTC-issued certificates and permits for purposes of the Takings Clause. The taxicab companies then sought review by the Supreme Court of Florida.The Supreme Court of Florida held that the 2017 repeal did not implicate the Florida Constitution’s Takings Clause. The Court concluded that the Legislature retained the discretion to revoke any property rights conveyed in the 2012 law, as the certificates and permits were revocable privileges rather than irrevocable property rights. Consequently, the repeal of the 2012 law did not constitute a taking requiring compensation. The Court approved the decision of the Second District Court of Appeal. View "Bojorquez v. State" on Justia Law