Justia Florida Supreme Court Opinion Summaries

In answering a question certified by the First District Court of Appeal the Supreme Court considered whether defense counsel's objection to a peremptory strike was properly renewed before the jury was sworn.The question in this case was whether a defendant who accepts a jury, but renewed a previously-raised objection to a state peremptory challenge after the challenged juror has been excused but before the jury is sworn, has waived that objection. The Supreme Court rephrased the question and answered the rephrased question in the negative, holding that a request for a standing objection to nonspecific things previously objected to in preliminary proceedings does not renew a specific objection to a peremptory challenge when the defense has prior to that request accepted the jury without reservation. View "State v. Ivey" on Justia Law

The Supreme Court affirmed the order of the trial court denying Defendant relief from his conviction and denied Defendant's habeas conviction, holding that Defendant was not entitled to relief.Defendant was found guilty of first-degree felony murder and robbery with a firearm or other deadly weapon. Defendant later moved for postconviction relief. The trial court vacated Defendant's death sentence and ordered a new penalty phase pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016). Defendant appealed the denial of his guilt phase claims and petitioned the Supreme Court for a writ of habeas corpus. In the appeal from the postconviction motion, the Supreme Court affirmed, holding that Defendant was not entitled to relief on his allegations of error. The Court then denied habeas relief, holding that appellate counsel was not ineffective on direct appeal. View "Jordan v. State" on Justia Law

The Supreme Court declined to answer a question certified by the Fourth District Court of Appeal regarding whether, under the Fourth Amendment, a warrantless blood draw of an unconscious person incapable of giving consent may be pursuant to Fla. Stat. 316.1932(1)(c) so that the unconscious person can be said to have "consented" to the blood draw, holding that this case fell squarely within the rule announced in Mitchell v. Wisconsin, 139 S. Ct. 2525 (2019).The Wisconsin Supreme Court analyzed the Fourth Amendment issue using the "consent" framework of the statute. During the pendency of this appeal the United States Supreme Court considered a materially indistinguishable issue relating to a similar Wisconsin statute and vacated the Wisconsin Supreme Court's decision. The Supreme Court declined to address the certified question as framed, applied Mitchell, vacated the Fourth District's decision, and remanded, holding that because this case fell within the rule announced in Mitchell, the warrantless blood draw was legal. View "McGraw v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying John Mack Sketo Calhoun's motion to vacate his conviction of first-degree murder filed under Fla. R. Crim. P. 3.851 and denied Calhoun's petition for a writ of habeas corpus, holding that Calhoun was not entitled to relief.Specifically, the Supreme Court held (1) as to Calhoun's postconviction appeal, the circuit court properly denied relief as to Calhoun's newly discovered evidence claim, trial counsel was not ineffective during the guilt phase, and none of Calhoun's remaining claims warranted relief; and (2) as to Calhoun's habeas petition, Calhoun failed to demonstrate that appellate counsel was ineffective on direct appeal. View "Calhoun v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court summarily denying as untimely Appellant's successive postconviction motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Appellant's motion was time barred.In his motion, Appellant argued that a diagnosis of gender dysphoria was newly discovered evidence that he was incompetent to plead guilty to first-degree murder, to waive a penalty phase jury, and to waive postconviction proceedings and counsel. The Supreme Court affirmed the circuit court's summary denial of the motion, holding that Appellant's motion was both time barred and not based upon newly discovered evidence. View "Rodgers v. State" on Justia Law

The Supreme Court approved the recommended sanctions of the Florida Judicial Qualifications Commission (JQC) concerning misconduct by Judge Robin C. Lemonidis of the Eighteenth Judicial Circuit, accepted a stipulation entered into by Judge Lemonidis and the JQC, and commanded Judge Lemonidis to appear before the Court for the administration of a public reprimand.This case arose from Judge Lemonidis's conduct in two incidents that occurred in two unrelated proceedings. The JQC charged Judge Lemonidis with violating the Code of Judicial Conduct and proposed that a public reprimand and continued participation in stress management counseling were appropriate sanctions. The parties executed a stipulation, in which Judge Lemonidis admitted to the conduct and accepted the recommended discipline. The Supreme Court concluded that the JQC's findings were supported by clear and convincing evidence and approved the JQC's recommended discipline and the parties' stipulation. View "Inquiry Concerning Judge Robin C. Lemonidis" on Justia Law

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