Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the circuit court dismissing in part and denying in part James Dailey's third successive motion for postconviction relief and also denied Dailey's motion for stay of execution and his petition for a writ of habeas corpus, holding that Dailey was not entitled to relief on any of his claims.Dailey was convicted of first-degree murder and sentenced to death. After his death warrant was signed, Dailey filed his third successive motino for postconviction relief, which the circuit court dismissed in part and denied in part. The Supreme Court affirmed the postconviction court's denial of relief and denied Dailey's habeas petition, holding (1) the circuit court properly rejected Dailey's claims that his execution would be unconstitutionally arbitrary; (2) the circuit court did not err in rejecting Dailey's claim that newly discovered evidence proved the State committed Brady and Giglio violations; (3) the circuit court did not err in denying Dailey's requests for certain public records; and (4) Dailey was procedurally barred from raising his claims in his habeas petition. View "Dailey v. State" on Justia Law

The Supreme Court affirmed the circuit court's summary denial of Appellant's second successive motion for postconviction relief, holding that the petition was both untimely and procedurally barred.Appellant was convicted of first-degree murder and sentenced to death. Several years later, Appellant filed his second successive motion for postconviction relief under Fla. R. Crim. P. 3.851, arguing that, in Buck v. Davis, 137 S. Ct. 759 (2017), the United States Supreme Court established a new fundamental constitutional right that the injection of racial bias and prejudice into a criminal trial constitutes per se ineffective assistance of counsel. Further, Appellant argued that this right applies to convictions and sentences, like his, that became final before Buck. The Supreme Court disagreed, holding (1) Appellant's motion was untimely because Buck did not establish a new right; and (2) because this Court previously addressed the arguments at issue and held that they did not warrant relief Appellant's motion was procedurally barred. View "Bell v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's successive motion for postconviction relief, holding that the circuit court properly denied relief.Appellant pleaded guilty to first-degree murder, sexual battery, and other crimes. The trial judge sentenced Appellant to death for the murder. The Supreme Court affirmed the convictions and sentences on direct appeal. Appellant later filed a successive postconviction motion under Fla. R. Crim. P. 3.851, arguing that his death sentence was unconstitutional under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 S. 3d 40 (Fla. 2016). The circuit court summarily denied the motion. The Supreme Court affirmed, holding that Appellant's claim was procedurally barred to the extent it was raised in his earlier postconviction appeal and, additionally, failed on the merits. View "Brant v. State" on Justia Law

The Supreme Court denied Petitioner's petition to invoke this Court's discretionary jurisdiction, holding that the Florida Constitution does not authorize the Supreme Court to review cases that "may present federal issues."Petitioner, an inmate, filed a motion for postconviction relief alleging ineffective assistance of counsel. The postconviction court denied the motion, ruling that Petitioner had failed to demonstrate prejudice. The court of appeals affirmed. Petitioner then filed a notice to invoke the Supreme Court's discretionary jurisdiction on the ground that the court of appeal's decision below "expressly and directly conflicts with the decision of another district court of appeal or the Florida Supreme Court." Petitioner's jurisdictional brief, however, did not identify a conflict case but instead stated that the case "may present federal issues." The Supreme Court denied relief, holding that because Petitioner's jurisdictional brief failed to identify a jurisdictional basis for the Court to consider his case, he was not entitled to review. View "Mallet v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying in part and dismissing in part Defendant's second successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that Defendant was not entitled to relief on his claim.In his second successive postconviction motion Defendant asserted that newly discovered evidence required that his conviction be overturned, that the State committed Brady and Giglio violations, and that his death sentence was unconstitutional because he was innocent of the murder. The circuit court denied relief. The Supreme Court affirmed, holding (1) all of Defendant's newly discovered evidence claims were either correctly rejected as untimely or based on inadmissible evidence; (2) each of Defendant's Giglio claims failed on the merits; (3) the lower court did not err in declining to take judicial notice of certain records; and (4) the circuit court did not err in summarily rejecting Defendant's claim that he is actually innocent. View "Dailey v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction and death sentence for first-degree murder, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Court held (1) the jury instructions during the penalty phase were sufficient; (2) the trial court did not err in admitting Defendant's letters to a predecessor judge and the elected state attorney; (3) the trial court's findings of the CCP aggravator were supported by competent, substantial evidence; (4) there was no error in the court's analysis of the prior violent felony aggravator; (5) the sentencing order was sufficient; (6) the evidence was sufficient to sustain the murder conviction; and (7) the death sentence was proportionate. View "Rogers v. State" on Justia Law

Based on Gregory Harris's persistent history of filing pro se petitions that were meritless or otherwise inappropriate for the Supreme Court's review, the Supreme Court held that Harris had abused the judicial process and burdened the Court's resources and that Harris's petition for a writ of habeas corpus filed in this case was a frivolous proceeding. Accordingly, the Court instructed the Clerk of the Court to reject any future pleadings, petitions, motions, documents, or other filings submitted by Harris relating to his criminal convictions for child abuse and grand theft unless such filings were signed by a member in good standing of The Florida Bar. View "Harris v. Inch" on Justia Law

Based on Donald Williams' persistent history of filing pro se petitions that were meritless or otherwise inappropriate for the Supreme Court's review, the Supreme Court held that Williams had abused the judicial process and burdened the Court's resources and that Williams' petition for a writ of habeas corpus filed in this case was a frivolous proceeding. Accordingly, the Court instructed the Clerk of the Court to reject any future pleadings, petitions, motions, documents, or other filings submitted by Williams relating to his criminal conviction for second-degree murder unless such filings were signed by a member in good standing of The Florida Bar. View "Williams v. Inch" on Justia Law

The Supreme Court affirmed the order of the postconviction court summarily denying Gary Ray Bowles' successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851 and denied Bowles' petition for a writ of habeas corpus and the motions to stay his execution, holding that Bowles was not entitled to relief.Bowles pleaded guilty to first-degree murder and was sentenced to death. In 2017, Bowles filed a successive postconviction motion, raising an intellectual disability claim for the first time. Bowles filed the final version of this motion after the governor signed his death warrant in 2019. The postconviction court denied the intellectual disability claim as untimely. Bowles appealed and also filed a habeas petition alleging that his execution would constitute cruel and unusual punishment. The Supreme Court affirmed the denial of postconviction relief and denied the habeas petition, holding (1) Bowles' intellectual disability claim was untimely; (2) the postconviction court did not abuse its discretion in denying Bowles' request for certain public records; and (3) because the United States Supreme Court has made clear that capital punishment does not constitute cruel and unusual punishment under the Eighth Amendment, this Court cannot invalidate Bowles' death sentence as cruel and unusual. View "Bowles v. State" on Justia Law

The Supreme Court quashed the decision of the Third District on the issue of whether a defendant is entitled to a de novo sentencing proceeding after an appellate court determines that the trial court's initial downward departure sentence was not supported by legally sufficient findings, holding that the proper remedy upon reversal of a sentence due to the invalidity of a downward departure is resentencing de novo.Defendant pled guilty to four offenses and was placed on probation. The trial court subsequently revoked Defendant's probation and imposed a downward departure from what otherwise would have been the lowest permissible sentence under the Criminal Punishment Code (CPC). The Third District concluded that the departure was invalid and remanded for "resentencing within the sentencing guidelines." The Supreme Court quashed the Third District's decision, holding that on remand for resentencing due to the substantive invalidity of a downward departure, the trial court is permitted to impose a downward departure as long as the departure comports with the principles and criteria of the CPC. View "Shine v. State" on Justia Law