Justia Florida Supreme Court Opinion Summaries

The Supreme Court quashed the decision of the Third District Court of Appeal concluding that Fla. Stat. 776.032(4) was a substantive change in the law and therefore did not apply retroactively, holding that section 776.032(4) is a procedural change in the law and applies to all Florida "Stand Your Ground" immunity hearings conducted on or after the statute's effective date.Section 776.032(4), which effective in June 2017 altered the burden of proof at pretrial immunity hearings under Stand Your Ground law, applies to pending cases involving criminal conduct committed prior to the effective date of the statute. In the instant case, Defendant's immunity hearing took place after the statute went into effect. The Third District concluded that section 776.032(4) did not apply retroactively, and therefore, the statute was inapplicable in this case. The Supreme Court quashed the decision below and remanded the case, holding (1) section 776.032(4) is a procedural change in the law and not categorically barred by Fla. Const. art. X, 9 from applying in pending cases; (2) the determination of whether a new procedure applies in a pending case generally depends on the posture of the case; and (3) applying section 776.032(4) in a pending case does not entail a retroactive application of the statute. View "Love v. State" on Justia Law

The Supreme Court dismissed Petitioner's petition for review of the decision of the Third District Court of Appeal concluding that Petitioner's "negligent security" claim against Miami-Dade County was barred by sovereign immunity, holding that the conflict issue in this case was a dead issue that has been resolved by this Court in previous opinions.Petitioner was shot and injured at a birthday party hosted at one of the County's public parks. The Third District concluded that Petitioner's personal injury claim was predicated on the County's alleged failure to allocate off-duty police officers to the party and that sovereign immunity protects the County's policy and planning decisions about where to allocate its limited police resources. The Third District reached its holding irrespective of any duty owed to Petitioner by the County. Petitioner petitioned for review, arguing that the existence of duty rendered sovereign immunity inapplicable. The Supreme Court dismissed Petitioner's petition for review without reaching the merits, holding that the merging of duty and sovereign immunity has already been resolved by this Court in opinions making clear that duty and sovereign immunity are not to be conflated. View "Sanchez v. Miami-Dade County" on Justia Law

The Supreme Court approved the decision of the Fifth District Court of Appeal in this insurance dispute, holding that an insurer that issues a reduced premium collector vehicle policy may not limit uninsured motorist coverage under the specialty policy to accidents involving the occupancy or use of the collector vehicle.The Estate of Michael Lentini, who was operating his motorcycle when he was involved in a fatal accident, sought uninsured motorist benefits under a policy issued on a collector vehicle. The policy limited uninsured motorist coverage to accidents involving the covered collector vehicle. The Insurer denied coverage, and the Estate sued. The trial court entered summary judgment for the Insurer. The Fifth District reversed, concluding that the collector vehicle policy must and did not comply with the statutory requirements of Fla. Stat. 627.727. The Supreme Court affirmed, holding that the requirements of section 627.727 prohibited the limitations placed on uninsured motorist coverage in the collector vehicle policy at issue in this case. View "American Southern Home Insurance Co. v. Lentini" on Justia Law

The Supreme Court answered a question certified to it by the First District Court of Appeal by holding that the private cause of action contained in Fla. Stat. 376.373(3) permits recovery for personal injury, thus receding from precedent.Plaintiff brought this suit alleging that Defendant was strictly liable for injuries he suffered after one of Defendant's tractor-trailers spilled battery acid onto the highway. Plaintiff filed his complaint under section 376.373(e), which imposes strict liability for the discharge of certain types of pollutants. The jury found the battery acid caused Plaintiff's injuries and awarded him more than $5 million in damages. The First District reversed, concluding that Curd v. Mosaic Fertilizer, LLC, 39 So. 3d 1216 (Fla. 2010), required it to apply the 1970 Pollutant Discharge Prevention and Control Act's definition of damages, which precluded Plaintiff's cause of action for personal injuries. The Supreme Court quashed the First District's decision, holding (1) Curd incorrectly applied the 1970 Act's definition of "damage" to a claim brought under the 1983 Act; and (2) the plain meaning of "all damages" in section 376.313(3) of the 1983 Act includes personal injury damages. View "Lieupo v. Simon's Trucking, Inc." on Justia Law

The Supreme Court approved the result of the decision of the First District Court of Appeal affirming Defendant's conviction for attempted second-degree murder with a weapon where the jury was given an erroneous jury instruction on the lesser included offense of attempted voluntary manslaughter with a weapon, holding that the trial court's unobjected-to, erroneous jury instruction did not constitute fundamental error.On appeal, the First District concluded that the erroneous jury instruction did not constitute fundamental error because the Supreme Court abrogated the jury pardon doctrine. The Supreme Court affirmed, holding that fundamental error did not occur in this case because there was no error in the jury instruction on the offense of conviction, the evidence supported that offense, and Defendant's constitutional rights were not violated even if Defendant was deprived of an opportunity for partial jury nullification. View "Knight 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 summary denial of the successive postconviction motion was appropriate in this case.Appellant was convicted of first-degree murder and sentenced to death. In his successive postconviction motion, Appellant claimed that he had newly discovered evidence of Brady and Giglio violations and that he was entitled to relief under Hurst v. State. 202 So. 3d 40 (Fla. 2016) and under changes to Florida's capital sentencing statute enacted after Hurst. The circuit court summarily denied the successive postconviction motion, concluding that the newly discovered evidence claim was procedurally barred and that the Hurst-related claims lacked merit. The Supreme Court affirmed, holding (1) the record conclusively refuted Appellant's newly discovered evidence claim; and (2) Hurst relief was not available to Appellant. View "Bogle v. State" on Justia Law

The Supreme Court affirmed the denial of Sparre's postconviction motion to vacate his conviction of first-degree murder and sentence of death filed under Fla. R. Crim. P. 3.851 and denied his petition for writ of habeas corpus, holding that Sparre was not entitled to relief.As to Sparre's appeal from the denial of his postconviction motion, the Supreme Court held (1) trial counsel was not ineffective, despite two instances in which counsel was deficient; (2) the trial court properly denied Sparre's claim that the cumulative effect of trial counsel's errors entitled him to relief; and (3) Sparre's claims that the postconviction court erred in three other respects were without merit. As to Sparre's habeas petition, the Court held that Sparre was not entitled to relief on his claims of ineffective assistance of appellate counsel. View "Sparre v. State" on Justia Law

The Supreme Court affirmed Defendant's sentence of death for the first-degree murder of Terrese Pernell Stevens, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Court held (1) the jury instructions were sufficient during the penalty phase; (2) the trial court did not err in concluding that the impaired capacity mitigating circumstance had not been proven; (3) the sentencing order was sufficient; (4) the trial court did not err when it found five mitigating circumstances were established but "not mitigating"; (5) Defendant's death sentence was proportionate; and (6) the trial court did not err in denying Defendant's motion to bar imposition of the death penalty due to intellectual impairment. View "Newberry v. State" on Justia Law

The Supreme Court affirmed the judgment of the postconviction court denying Defendant's guilt phase claims in his initial postconviction motion filed under Fla. R. Crim. P. 3.851, holding that the postconviction court did not err in denying relief.Specifically, the Court held that the postconviction court did not err in denying Defendant's (1) claim alleging newly discovered evidence; (2) six claims alleging ineffective assistance of counsel; (3) claim alleging cumulative error where the alleged individual errors were without merit; and (4) claim alleging that he may be incompetent at the time of execution where a death warrant had not been issued in this case. View "Matthews v. State" on Justia Law

The Supreme Court sanctioned Defendant by directing the clerk of court to reject any future pleadings or other requests for relief submitted by Defendant related to three criminal cases, unless such filings were signed by a member in good standing of The Florida Bar, holding that Defendant had abused the Court's limited judicial resources.Defendant, an inmate, filed a pro se petition to invoke the Supreme Court's all writs jurisdiction. The Supreme Court dismissed the petition and retained jurisdiction to pursue possible sanctions. The Court then found that Defendant failed to show cause why he should not be barred. Specifically, the Court found that Defendant demonstrated a pattern of vexatious filing of meritless pro se requests for relief in the Supreme Court. The Court then found that Defendant failed to show cause why sanctions should not be imposed and sanctioned Defendant accordingly. View "Baysen v. State" on Justia Law