Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s convictions of first-degree murder and six sentences of death, holding that no reversible error occurred in the proceedings below and that each of the death sentences was appropriate.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion when it declined Defendant’s request for self-representation; (2) there was no improper doubling of aggravators; (3) Defendant’s challenge to the constitutionality of the death penalty was procedurally barred; (4) Defendant’s guilty pleas were knowing, intelligent, and voluntary; and (5) each of Defendant’s death sentences was proportionate. View "Damas v. State" on Justia Law

The Supreme Court accepted a question certified to it by the Second District Court of Appeal as to whether the pre-2014 version of Rule Regulating the Florida Bar 4-3.4(b) prevents the prevailing party in the underlying case from taxing as costs certain payments made to fact witnesses, answering that the party here was not permitted to pay a fact witness for the witness’s assistance with case and discovery preparation that was not directly related to the witness preparing for, attending, or testifying at proceedings.Rule 4-3.4(b) addresses witness payments and the prohibition against offering inducements to witnesses. In this dispute over the recoverable amount of prevailing party fees and costs, the Second District concluded that payments made to fact witnesses for their “assistance with case and discovery preparation” were permitted under rule 4-3.4(b) and were thus recoverable. The Supreme Court accepted certification and held (1) Rule 4-3.4(b) permits a party to pay a fact witness for the witness’s assistance with case and discovery preparation that is directly related to the witness preparing for, attending, or testifying at proceedings; and (2) this case must be remanded because it is unclear which witness payments were included in the trial court’s cost award. View "Trial Practices, Inc. v. Hahn Loeser & Parks, LLP" on Justia Law

The Supreme Court quashed the decision of the Fifth District Court of Appeal expressly construing a provision of the Florida Constitution and upheld the validity of an ordinance proposing an amendment to the Orange County Charter with the exception of certain language discussed in this opinion, holding that the language was in direct conflict with Fla. Stat. 100.041.The proposed amendment provided for term limits and non-partisan elections for county constitutional officers. Three Orange County constitutional officers filed a suit for declaratory and injunctive relief against the County challenging the county ordinance. The trial court upheld the portion of the charter amendment providing for term limits but struck down that portion providing for nonpartisan elections. The Fifth District affirmed. The Supreme Court quashed the decision below and upheld the validity of the ordinance upon the severance therefrom of offending language requiring the county constitutional officers to be elected during the primary election, holding that the offending language in the amendment for county constitutional officers to be elected on a nonpartisan basis may be stricken without rendering the remainder incomplete. View "Orange County, Florida v. Singh" on Justia Law

The Supreme Court affirmed the circuit court’s order denying in part and dismissing in part Appellant’s successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief on any of his claims.Appellant was convicted of first-degree murder, sexual battery with great force, and burglary with assault. The jury recommended a death sentence by a vote of eight to four, and the trial court accepted the recommendation. In his successive postconviction motion to vacate his death sentence, Appellant raised claims under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The circuit court summarily denied the claim. The Supreme Court affirmed, holding (1) Hurst and Hurst v. Florida did not apply to Appellant; and (2) Appellant was not entitled to relief on his other claims. View "Reese v. State" on Justia Law

The Supreme Court approved the result reached by the First District Court of Appeal affirming the trial court’s rejection of Petitioners’ challenge to the State’s K-12 public education system based on the State’s alleged failure to comply with Fla. Const. art. IX, 1(a), holding that Coalition for Adequacy & Fairness in School Funding, Inc. v. Chiles (Coalition), 680 So. 2d 400 (Fla. 1996) defeated Petitioners’ claim.In their complaint, Petitioners sought a declaration that the State was breaching its duty to make adequate provision for an “efficient” and “high quality” system of free public schools that allows students to obtain a high quality education. Petitioners requested that the courts order the State to establish a remedial plan including studies to determine what resources are necessary to provide a high quality education to Florida students. The trial court rejected Petitioners’ challenge, and the court of appeal affirmed. The First Circuit affirmed, holding that because Petitioners failed to present any manageable standard by which to avoid judicial intrusion into the powers of the other branches of government, the court of appeal properly affirmed the trial court’s rejection of Petitioners’ blanket challenge to the adequacy of the funding of the entire K-12 education system. View "Citizens for Strong Schools, Inc. v. State Board of Education" on Justia Law

The Supreme Court quashed the decision of the Third District Court of Appeal regarding whether proposals for settlement made pursuant to Fla. Stat. 768.79 and Fla. R. Civ. P. 1.442 must comply with the email service provisions of Florida Rule of Judicial Administration 2.516, holding that proposals for settlement are not subject to the email service requirement of rule 2.516.The trial court in this case denied Petitioner’s motion to enforce her proposal for settlement because Petitioner’s email to Respondent containing the proposal for settlement did not strictly comply with all of the formatting requirements set forth in the rule 2.516. The Third District Court of Appeal affirmed. The Supreme Court quashed the decision below, holding (1) the Third District erred in finding that a proposal for settlement is subject to the requirements of rule 2.516; and (2) even if rule 2.516 applied to proposals for settlement, Petitioner’s failure to comply with the email formatting requirements set forth in the rule would not render the proposal unenforceable because the proposal complied with the substantive requirements set forth in section 768.79. View "Wheaton v. Wheaton" on Justia Law

The Supreme Court approved in part and quashed in part the decision of the Second District Court of Appeal in this case and remanded the case for further proceedings, holding that the trial court erred in denying Appellant’s motion for a judgment of acquittal as to first-degree premeditated murder and that Appellant was entitled to resentencing.A jury found Appellant guilty of first-degree murder and other crimes. The court of appeal affirmed Appellant’s convictions and sentences. The Supreme Court approved in part and quashed in part the court of appeal’s decision, holding (1) because Appellant presented a prima facie case of self-defense and the State did not refute Appellant’s claim beyond a reasonable doubt, the trial improperly denied Appellant’s motion for a judgment of acquittal as to the first-degree premeditated murder count; (2) the trial court did not err in denying the motion as to the attempted murder count; and (3) Appellant was entitled to resentencing. View "Williams v. State" on Justia Law

The Supreme Court quashed the decision of the Fourth District Court of Appeal on the question of whether a voluntary dismissal provides a basis for being considered the prevailing party for the purpose of appellate attorney fees, holding that the court of appeal improperly denied appellate attorney’s fees based on the bank’s voluntary dismissal of the appeal.Appellant, a homeowner, sought appellate attorney’s fees pursuant to Fla. Stat. 57.105(7) after a bank filed a notice of voluntary dismissal in the court of appeal. The court of appeal concluded that Appellant was not entitled to appellate attorney’s fees because she prevailed on her standing argument presented in the trial court. The Supreme Court quashed the decision below, holding (1) caselaw makes clear that a voluntary dismissal of an appeal renders the opposing party the prevailing party for the purpose of appellate attorney fees; and (2) Appellant was entitled to appellate attorney fees because the bank maintained its right to enforce the reverse mortgage contract in its appeal until the dismissal. View "Glass v. Nationstar Mortgage, LLC" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant’s motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding, among other things, that Appellant’s attorney was not ineffective for failing to investigate and present certain mitigation evidence.Appellant was convicted of kidnapping and first-degree murder and sentence of death. In her motion for postconviction relief Appellant raised fourteen initial claims and then amended her motion to add a Hurst claim. The trial court denied the motion in its entirety. The Supreme Court affirmed, holding that trial counsel’s performance was not deficient, the State did not commit a Giglio violation, and Appellant was not entitled to a new penalty phase under Hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State, 202 So. 3d 40 (Fla. 2016). View "Allen v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Appellant’s motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Hurst v. State, 202 So. 3d 40 (Fla. 2016), did not apply retroactively to Appellant’s sentence of death.Appellant was convicted of first-degree murder and sentenced to death. The jury recommended death by a vote of seven to five. Appellant’s death sentence became final in 1993. In his postconviction motion, Appellant sought relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst. The Supreme Court affirmed the postconviction court’s order denying relief, holding that Appellant was not entitled to relief under Hurst. View "Thompson v. State" on Justia Law