Justia Florida Supreme Court Opinion Summaries

After denying Ronald K. Schiming’s petition for a writ of habeas corpus as repetitive, the Supreme Court instructed the Clerk of Court to reject any future pleadings, petitions, motions, documents, or other filings submitted by Schiming related to case number 481987CF005037000AOX, unless such filings are signed by a member in good standing of The Florida Bar. Where Schiming had a persistent history of filing pro se petitions that were frivolous, meritless, or otherwise inappropriate for the Supreme Court’s review, the Court found that Schiming had abused the judicial process and burdened the Court’s limited judicial resources. View "Schiming v. Jones" on Justia Law

The Supreme Court affirmed the postconviction court’s denial of Appellant’s successive motion to vacate judgments of conviction, including one of first-degree murder, and sentence of death under Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief.Specifically, the Supreme Court held (1) Hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State, 202 So. 3d 40 (Fla. 2016) were applicable to Appellant’s case, but the Hurst error in this case was harmless beyond a reasonable doubt; and (2) Appellant was not entitled to relief on his Hurst-induced claim under Caldwell v. Mississippi, 472 U.S. 320 (1985), or his claim that he was entitled to application of chapter 2017-1, Laws of Florida. View "Conahan v. State" on Justia Law

For the reasons discussed in this opinion, by a prior order, Dana Marie Santino was removed from office on the grounds that Santino’s conduct “does not evidence a present fitness to hold judicial office.”On July 2, 2018, the Supreme Court issued an order removing Santino from the office of county judge of Palm Beach County, Florida. Here, the Court provided an opinion explaining the reasons for removal. The Judicial Qualifications Commission hearing panel concluded that Santino violated Judicial Canons 7A(3)(a), (3)(b), (3)(c), (e)(i), and (e)(ii) and Rule 4-8.2(a) and (b) of the Rules of Professional Conduct for making false and misleading statements about her opponent, Gregg Lerman, in e-mail advertisements and on social media during her 2016 election campaign and recommended that she be removed from office. The Supreme Court held that Santino’s campaign misconduct warranted removal under these facts. View "Inquiry Concerning Judge Dana Marie Santino" on Justia Law

The Supreme Court affirmed Defendant’s sentence of death after resentencing, holding that any error in Defendant’s resentencing did not taint the jury’s recommendation for death.Defendant was convicted for the 1990 first-degree murder of Donna Burnell. The trial court sentenced Defendant to death after the new penalty phase jury recommended the death penalty by a vote of twelve to zero. On appeal, Defendant raised several claims, including a Hurst v. Florida, 136 S. Ct. 616 claim and a claim that his death sentence was disproportionate. The Supreme Court affirmed the death sentence, holding (1) Defendant’s arguments either involved no errors or errors that were harmless and not prejudicial; and (2) the cumulative effect of any errors did not deprive Defendant of a fair penalty phase hearing. View "Lowe v. State" on Justia Law

The Supreme Court reversed the decision of the circuit court in granting a petition for writ of quo warranto and ordering that ballot titles and summaries of three proposed amendments to the Florida Constitution be stricken from the November 2018 general election ballot, holding that the petition was improperly granted.The amendments at issue were Amendments 7, 9, and 11. In reversing the decision of the circuit court and ordering that the amendments appear on the ballot for the November 2018 general election, the Supreme Court held that the circuit court (1) abused its discretion in granting the petition because the standard for obtaining quo warranty relief was not satisfied; and (2) incorrectly found any deficiency in the proposals or ballot summaries on the merits. View "Detzner v. Anstead" on Justia Law

The Supreme Court affirmed the decision of the circuit court granting summary judgment in favor of the League of Women Voters and enjoining Kenneth Detzner, Secretary of the Florida Department of State, from placing Revision 8 on the ballot for the November 2018 general election, holding that the ballot language was defective.The revision at issue sought to revise Article IX, Section 4(b) of the Florida Constitution and allow the power to authorize new charter schools to be assigned to any of a variety of potential public or private entities, rather than district school boards. The circuit court concluded that both the ballot text and summary failed to inform voters of the chief purpose and effect of the proposal and that the ballot summary was affirmatively misleading. The Supreme Court affirmed, holding that the ballot summary failed to inform voters of the revision’s true meaning and ramifications, and therefore, the ballot language was clearly and conclusively defective. View "Detzner v. League of Women Voters of Florida" on Justia Law

The Supreme Court affirmed the circuit court’s order summarily denying Appellant’s successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that Defendant was not entitled to Hurst relief, nor was he entitled to relief on his other claims.Appellant was convicted of first-degree murder. The jury recommended a death sentence by a vote of ten to two. The trial judge imposed a sentence of death. In his successive motion for postconviction relief, Appellant raised four claims based on Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The trial court denied the motion. The Supreme Court affirmed, holding (1) because Appellant’s sentence became final prior to Ring v. Arizona, 536 U.S. 584 (2002), Appellant was not entitled to Hurst relief; and (2) Appellant was not entitled to relief on his other claims. View "Jones v. State" on Justia Law

The Supreme Court quashed the decision of the Fourth District Court of Appeal in this criminal case, holding that the State was not entitled to the speedy trial rule’s recapture period in Fla. R. Crim. P. 3.191, where the State informed Defendant that it had terminated its prosecutorial efforts and failed to notify Defendant that new and different charges based on the same conduct were filed before the speedy trial period expired.The State charged Defendant with tampering with a witness and later dismissed the charges. After the speedy trial period expired, Defendant became aware of new charges based on the same conduct. The trial court granted Defendant’s motion for discharge without allowing the State the opportunity to try Defendant within the recapture period. The Fourth District reversed, receding from its prior decisions requiring that the defendant be notified of the charges within the speedy trial period. The Supreme Court quashed the decision below, holding that, under the circumstances in this case, the trial court correctly denied the State the recapture period and discharged Defendant. View "Born-Suniaga v. State" on Justia Law

The Supreme Court held that chapter 2013-107, section 1, Laws of Florida, which revised section 90.702, Florida Statutes, which the Court previously declined to adopt to the extent it was procedural, infringes on the Court’s rulemaking authority.After developing mesothelioma, Plaintiff filed this personal injury action claiming that sixteen defendants caused him to be exposed to asbestos. The trial court awarded Plaintiff $8 million in damages apportioned to certain defendants. At issue on appeal was the admission of expert causation testimony. The Fourth District Court of Appeal reviewed the admission of the experts testimony under Daubert v. Merrell Dow Pharmaceuticals, Inc. 509 U.S. 579 (1993), found that the trial court failed properly to exercise its gatekeeping function as to three experts, and reversed for a new trial as to R.J. Reynolds and remanded for entry of a directed verdict for Crane Co. The Supreme Court quashed the decision below, holding (1) Frye v. United States, 293 F. 1013 (D.C. Cir. 1923), not Daubert, is the appropriate test for Florida courts to determine the reliability of expert testimony before allowing it to be admitted into evidence; and (2) because the causation of mesothelioma is neither new nor novel, the trial court’s acceptance of the expert testimony was proper. View "DeLisle v. Crane Co." on Justia Law

The Supreme Court affirmed the circuit court’s order denying Appellant’s successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief on his claims.Appellant was convicted of first-degree murder and other offenses. The jury unanimously recommended a sentence of death by a vote of twelve to zero. Appellant later filed a successive postconviction motion to vacate his death sentence in light of hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). The postconviction court denied relief relief after an evidentiary hearing. The Supreme Court affirmed, holding (1) any Hurst error was harmless beyond a reasonable doubt; and (2) Appellant’s remaining claims were similarly without merit. View "Anderson v. State" on Justia Law