Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed the decisions of the circuit court denying Appellant's successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851 and Appellant's request for additional public records filed under Fla. R. Crim. P. 3.852(i), holding that there was no error.In 2012, Appellant was convicted of first-degree murder and sentenced to death. The circuit court later vacated Appellant's death sentence based on Hurst v. Stat, 202 So. 3d 40 (Fla. 2020), and ordered a new penalty phase. While Appellant's appeal in Calhoun II was pending, Appellant filed the successive postconviction motion at issue, raising a newly discovered evidence claim based on a purported jailhouse confession. On remand from Calhoun II, the circuit court denied Appellant's successive postconviction motion and his motion seeking additional public records. The Supreme Court affirmed the circuit court's denials of Appellant's successive postconviction motion and of his request for additional public errors, holding that the circuit court did not err or abuse its discretion. View "Calhoun v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeal concluding that the appellate court, exercising its authority to issue an interlocutory writ of certiorari, could not immediately review a trial court's ruling denying Petitioners' motion to dismiss a medical malpractice action brought them on the basis that Respondent's proposed expert did not meet the requirements of the Medical Malpractice Act, Fla. Stat. 766, holding that there was no error.Respondent sued Petitioners for medical malpractice and included within her presuit notices the affidavit of Dr. James DeStephens. Petitioners moved to dismiss the complaint on the grounds that DeStephens did not satisfy the statutory requisites. The circuit court denied the motion to dismiss, after which Petitioners filed a certiorari petition. The court of appeal dismissed the petition for lack of jurisdiction on the basis that Respondent had not established irreparable harm. The Supreme Court affirmed on different grounds, holding that it was Petitioners' failure to show that the trial court had departed from the essential requirements of the law, not their failure to demonstrate irreparable harm, that kept them from establishing their entitlement to relief. View "University of Fla. Bd. of Trustees v. Carmody" on Justia Law

The Supreme Court affirmed Defendant's sentence of death imposed by the trial court following the Supreme Court's reversal of his original death sentence and remand for resentencing, holding that relative culpability review could not provide a basis for vacating Defendant's death sentence.Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court overturned the death sentence on the ground that the trial court improperly relied on extrarecord facts and remanded for the limited purposes of resentencing and a new sentencing order. On remand, the trial court again sentenced Defendant to death. On appeal, Defendant argued that relative culpability review required that his sentence be reduced to life imprisonment because his equally culpable codefendant was sentenced to life imprisonment by the same judge. At issue was whether relative culpability review survived Lawrence v. State, 308 So. 3d 544 (Fla. 2020). The Supreme Court affirmed, holding (1) this Court's relative culpability review was a corollary of its comparative proportionality review, which Lawrence held to be violative of the Florida Constitution; and (2) therefore, relative culpability review was rendered obsolete by the Lawrence decision and could not provide a basis for vacating Defendant's death sentence. View "Cruz v. State" on Justia Law

The Supreme Court denied Appellant's petition for a writ of habeas corpus, holding that Appellant failed to establish that he was entitled to the writ.Appellant was convicted in 1991, following a jury trial, of first-degree murder and kidnapping. Decades later, Appellant filed his petition for a writ of habeas corpus. In his petition, Appellant claimed that Chapter 2017-1, Laws of Florida, created a substantive right that must be retroactively applied under the state and federal Constitutions. The Supreme Court denied relief, holding that this Court had consistently rejected as without merit the claim that chapter 2017-1 created a substantive right that must be retroactively applied, and Appellant's arguments did not compel departing from precedent. View "Arbelaez v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's motions in this criminal case in which Appellant was under a death warrant, holding that Appellant was not entitled to relief.Defendant was convicted of the murders of two women and sentenced to death. The United States Supreme Court denied certiorari review in 1992. After the governor signed a death warrant for one murder and scheduled the execution for June 15, 2023 Appellant sought relief in the circuit court, without success. The Supreme Court affirmed, holding that the circuit court did not err in (1) summarily denying Defendant's fourth postconviction motion under Fla. R. Crim. P. 3.851; (2) denying Defendant's motion for competency determination; and (3) denying Defendant's motion for MRI and PET scan. The Court also denied Defendant's motion for stay of execution. View "Owen v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition for a writ of prohibition challenging the trial court's rulings in criminal cases and a separate civil case, holding that Petitioner failed to show cause why he should not be pro se barred for his repeated misuse of the Court's limited resources.Petitioner, an inmate whose most recent conviction was for possession of a controlled substance, began filing petitions in the Supreme Court in 2018 pertaining to several different criminal cases and a dependency case regarding his children. Petitioner filed the instant prohibition petition challenging the trial court's denial of a motion and seeking to dismiss the case. The Supreme Court denied the petition and directed Petitioner to show cause why he should not be barred from filing further pro se requests for relief. The Supreme Court then sanctioned Petitioner, holding that Petitioner had abused the Court's limited judicial resources. View "Hill v. State" on Justia Law

The Supreme Court denied Petitioner's petition for a writ of habeas corpus and then sanctioned him, holding that Petitioner failed to show cause why he should not be pro se barred.In 2006, Petitioner was sentenced to life imprisonment as a prison releasee reoffender on two counts of kidnapping, and the court of appeal affirmed. Since 2006, the Petitioner "engaged in a vexatious pattern of filing meritless requests for relief" in the Supreme Court pertaining to his convictions and sentences, none of which merited relief. In the instant habeas petition, Petitioner raised several claims relating to the circuit court's 2006 judgment and sentence. The Supreme Court denied the petition and directed Petitioner to show cause why he should not be barred from filing further pro se requests for relief. The Supreme Court sanctioned Petitioner as pro se barred, holding that Petitioner failed to show cause why he should not be sanctioned for his abusive conduct. View "Steiner v. Dixon" on Justia Law

The Supreme Court approved the decision of the First District Court of Appeal affirming the trial court's judgment concluding that this negligence action was untimely filed, holding that Fla. Stat. 733.710(1) extinguished the claim at issue in this case.Petitioners, who were injured in an accident by Thomas Morton, sued Morton's estate for negligently operating the car and his employer, the Lewis Bear Company (LBC), for vicarious liability under the doctrines of respondeat superior and dangerous instrumentality. The trial court ruled (1) section 733.710(1) barred Petitioners' action against the estate because they failed to file their claims within two years of Morton's death; and (2) because the Estate could not be held liable, LBC could not be held vicariously liable. The court of appeal affirmed. The Supreme Court affirmed, holding (1) because Petitioners' claims against the estate were filed beyond section 733.710(1)'s deadline and did not qualify under an exception, they were barred; and (2) the court of appeal correctly held that section 733.710(1)'s statute of non claim exonerated LBC from vicarious liability for Morton's negligence. View "Tsuji v. Fleet" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of first-degree murder but set aside and his sentences of death for each murder, holding that Defendant was deprived of his right to "have the Assistance of Counsel for his defense" when the trial court put him to an improper choice at the beginning of the penalty phase proceedings.After the jury returned guilty verdicts for both first-degree murder charges the matter proceeded to the penalty phase. The jury unanimously recommended sentences of death. After a series of Spencer hearings, the trial court sentenced Defendant to death for each murder. The Supreme Court affirmed and remanded the case for a new penalty phase, holding (1) the trial court did not commit reversible error in its evidentiary rulings during Defendant's guilt phase proceedings; (2) Defendant's convictions were supported by competent, substantial evidence; but (3) Defendant's waiver of his right to counsel during the penalty phase was not knowing, intelligent, and voluntary, and Defendant was entitled to a new sentencing hearing based on the trial court's fundamental error in forcing him to abandon counsel during that phase. View "Figueroa-Sanabria v. State" on Justia Law

The Supreme Court denied a petition filed by Petitioner Andrew H. Warren, the elected State Attorney for the Thirteenth Judicial Circuit, arguing that Governor Ron DeSantis lacked authority to issue Executive Order 22-176 suspending him on the grounds of neglect of duty and incompetence, holding that the petition is denied on the ground of unreasonable delay.Within two weeks of his suspension Petitioner sued in federal district court requesting a writ of quo warranto on the basis that the suspension order was facially insufficient under Florida law. The federal court dismissed the claim. More than six months after Governor DeSantis issued the executive order at issue Petitioner filed this petition requesting the issuance of a writ of quo warranto and, alternatively, seeking a writ of mandamus ordering the Governor to reinstate him. The Supreme Court denied the petition, holding that, under the circumstances involving "dilatory conduct" on the part of Petitioner, this Court declines to consider Petitioner's claims for relief. View "Warren v. DeSantis" on Justia Law