Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the post conviction court denying Appellant's motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the postconviction court properly denied all claims argued in this appeal.In his postconviction motion Defendant raised several ineffective assistance of counsel claims, as well as a claim alleging retroactive application of Riley v. California, 573 U.S. 373 (2014). The postconviction court entered an amended order denying relief on all claims. The Supreme Court affirmed, holding (1) the alleged failures on the part of defense counsel did not rise to the level of ineffective assistance of counsel; and (2) Defendant's claim that he was entitled to a new trial under Riley was procedurally barred because Defendant failed to raise this claim on direct appeal. View "Smith v. State" on Justia Law

The Supreme Court affirmed the judgment of the post conviction court summarily denying Defendant's eighth successive motion to vacate his judgment of conviction and sentence, holding that all of Defendant's postconviction claims were legally insufficient or based on allegations that were conclusively refuted by the record.Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed. This case concerned Defendant's eighth successive motion to vacate the judgment of conviction and sentence. Along with his eighth successive motion Defendant filed a motion to compel discovery documents from the Office of the State Attorney. The postconviction court summarily denied Defendant's eighth successive postconviction motion and denied his motion to compel. The Supreme Court affirmed, holding (1) Defendant was not entitled to an evidentiary hearing on a newly discovered evidence claim alleging spoliation of evidence and a Brady violation; (2) Defendant was not entitled to an evidentiary hearing on his ineffective assistance of counsel claims; (3) the trial court did not err in summarily denying a standalone actual innocence claim; and (4) because Defendant failed to demonstrate his entitlement to the requested records the postconviction court correctly denied his motion to compel. View "Sweet v. State" on Justia Law

In this advisory opinion, the Supreme Court approved for placement on the ballot a proposed amendment entitled "Voter Approval of Constitutional Amendments," holding that the proposed amendment complies with the single-subject requirement of Fla. Const. art. XI, 3 and that the ballot title and summary comply with Fla. Stat. 101.161(1).The proposed amendment would amend sections 5 and 7 of article XI of the Florida Constitution. The Attorney General petitioned the Supreme Court for an opinion on whether the proposed amendment was valid. The Supreme approved the proposed amendment for placement on the ballot, determining (1) the proposed amendment meets the single-subject requirement; and (2) the ballot title and summary comply with section 101.161(1). View "Advisory Opinion to the Attorney General re Voter Approval of Constitutional Amendments" on Justia Law

The Supreme Court affirmed the order of the circuit court denying in part Marvin Cannon's initial postconviction motion filed pursuant to Fla. R. Crim. P. 3.851 and denied Cannon's petition for writ of habeas corpus, holding that Cannon was not entitled to relief on his claims.Cannon was convicted of first-degree murder and other crimes and sentenced to death. Cannon later filed his initial motion for postconviction relief, asserting that he was entitled to resentencing under Hurst v. State, 202 So. 3d 40 (Fla. 2016), that counsel was ineffective, and that the Department of Corrections' website reflected he was still serving a fifteen-year sentence for attempted robbery even though that conviction was vacated on direct appeal. The trial court agreed with Cannon's Hurst claim and vacated his death sentence but denied the remaining claims. The Supreme Court affirmed, holding that Cannon was not denied constitutionally effective assistance of counsel and that the postconviction court properly denied Cannon's second claim. In his habeas petition, Cannon alleged ineffective assistance of appellate counsel. The Supreme Court denied the petition, holding that appellate counsel was not ineffective for failing to raise a procedurally barred claim. View "Cannon v. State" on Justia Law

The Supreme Court affirmed Defendant's sentence of death imposed in connection with his conviction for the murder of a fellow prison inmate, holding that Defendant's claims on appeal were without merit and that Defendant's death sentence was proportionate in comparison to other capital cases.Specifically, the Supreme Court held (1) the trial court did not err in failing to instruct the jury that it must find beyond a reasonable doubt that the aggravating factors were sufficient to warrant a death sentence and that they outweighed the mitigating factors; (2) the trial court adequately considered Defendant's request for a nonbinding recommendation to the Department of Corrections and did not act under any mistaken impression of the law; and (3) Defendant's sentence was proportional. View "Doty v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Appellant's third successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851, holding that Appellant's claims were procedurally barred as untimely.Appellant was convicted of first-degree murder and sentenced to death. Fourteen years later, Appellant filed his third successive postconviction motion, asserting that the State committed a Brady violation and a Giglio violation and, alternatively, that defense counsel was ineffective and that newly discovered evidence was likely to produce an acquittal at retrial. The postconviction court denied the claims on the merits after holding an evidentiary hearing. The Supreme Court affirmed but on other grounds, holding that the claims raised in Appellant's third successive postconviction motion were untimely because they because discoverable through due diligence more than a year before the motion was filed. View "Mungin v. State" on Justia Law

The Supreme Court quashed the decision of the First District Court of Appeal regarding whether the circuit court presiding over a foreclosure action has continuing jurisdiction to consider a third-party purchaser's motion to recover the value of repairs and improvements made to the property he purchased at a foreclosure sale that was later vacated, holding that the circuit court had continuing jurisdiction to consider the purchaser's motion for damages.The First District concluded that the circuit court did not have jurisdiction to entertain the purchaser's third-party motion for damages after it rendered the final judgment of foreclosure. The Supreme Court disagreed and quashed the First District's decision, holding that the circuit court presiding over the foreclosure action had continuing jurisdiction to consider the purchaser's motion for damages for repairs and improvements he made to the property he purchased at the foreclosure sale that was later vacated. View "Griffin v. LaSalle Bank, N.A." on Justia Law

The Supreme Court quashed the decision of the First District Court of Appeal vacating Defendant's sentence and remanding for resentencing under the prior version of Fla. Stat. 775.082(1), which could have resulted in reimposition of Defendant's sentence without any findings by a jury or the trial court, holding that the proper remedy for harmful error resulting from the court, not the jury finding the fact of dangerousness under section 775.082(1) is to remand for resentencing.In Brown v. State, 260 So. 3d 147, 150 (Fla. 2018), the Supreme Court held that the portion of section 775.082(10) requiring the court, not the jury, to find the fact of dangerousness to the public necessary to increase the statutory maximum nonstate prison sanction violated the Sixth Amendment. At issue in this case was the proper remedy for harmful error resulting from the court finding the fact of dangerousness under the statute. The First District held that statutory revival was the proper remedy. The Supreme Court quashed the First District's decision, holding that the proper remedy is to remand for resentencing with instructions to either impose a nonstate sanction of up to one year in county jail or empanel a jury to make the determination of dangerousness, if the State so requests. View "Gaymon v. State" on Justia Law

The Supreme Court answered a certified question by concluding that Fla. R. App. P. 9.130(a)(3)(C)(xi) does not permit an appeal of a non-final order denying immunity if the record shows that the defendant is entitled to immunity as a matter of law but the trial court did not explicitly preclude it as a defense.Plaintiff sued the Florida Highway Patrol (FHP), alleging negligence. FHP moved for summary judgment, arguing that it was protected by sovereign immunity. The trial court denied the motion. FHP appealed the non-final order, relying on the sovereign immunity subdivision of rule 9.130 as the basis for the district court's jurisdiction. The First District Court of Appeal dismissed the appeal. The panel then certified the question at issue in this case as a question of great public importance. The Supreme Court answered the question in the negative, holding that rule 9.130(a)(3)(C)(xi) in its current form insufficiently protects the interests underlying sovereign immunity. The Court then approved the decision of the First District. View "Florida Highway Patrol v. Jackson" on Justia Law

The Supreme Court affirmed in part and reversed in part the trial court's judgment ordering a new penalty phase proceeding after finding Defendant was entitled to relief under Hurst v. State, 202 So. 3d 40 (Fla. 2016), and rejecting Defendant's guilt-phase claim, holding that this Court must partially recede from Hurst.The jury in Defendant's case recommended death by a vote of eleven to one after unanimously finding that, during the course of the first-degree murder, Defendant committed related crimes. Defendant later filed his postconviction motion alleging that counsel was ineffective for conceding that Defendant committed the nonhomicide offenses for which he was convicted and that Defendant was entitled to resentencing because the jury did not make the findings required by Hurst. The trial court denied Defendant's ineffective assistance of counsel claim but vacated Defendant's death sentence pursuant to Hurst. The Supreme Court reversed in part, holding (1) this Court recedes from Hurst except to the extent it requires a jury unanimously to find the existence of a statutory aggravating circumstance; and (2) under a correct understanding of Hurst v. Florida, 136 S. Ct. 616 (2016), the requirement that a jury unanimously find a statutory aggravating circumstance beyond a reasonable doubt was satisfied in this case. View "State v. Poole" on Justia Law