Justia Florida Supreme Court Opinion Summaries

Fla. Stat. 702.06 permits an independent action at law for a deficiency judgment when the foreclosure court has expressly reserved jurisdiction to handle a deficiency claim but has not actually decided the merits of the claim.Heather Lanham’s residential property was foreclosed by final judgment that expressly reserved jurisdiction to rule on any future deficiency claim. Dyck-O’Neal, Inc., which was assigned the mortgage and note, filed a separate action at law against Lanham seeking a deficiency judgment. The trial court granted summary judgment for Lanham. The First District Court of Appeal quashed the trial court’s decision, concluding that the trial court lacked subject matter jurisdiction over the suit under Fla. Stat. 702.06 because the foreclosure court previously had reserved jurisdiction to handle the deficiency claim. The Supreme Court quashed the decision below, holding that section 702.06 plainly precludes the separate action only where the foreclosure court has actually ruled on the claim. View "Dyck-O'Neal, Inc. v. Lanham" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellant’s motion filed pursuant to Fla. R. Crim. P. 3.851, which sought relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and the Supreme Court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016).Appellant was sentenced to death following a jury’s unanimous recommendation for death. The death sentence became final in 2001. In affirming the denial of Appellant’s motion, the Supreme Court held that Hurst does not apply retroactively to Mansfield’s sentence of death. View "Mansfield v. State" on Justia Law

Under federal law, the Agency for Health Care Administration (AHCA) may only reach the past medical expenses portion - and not the future medical expenses portion - of a Medicaid recipient’s tort recovery to satisfy its Medicaid lien.Florida’s Medicaid program, administered by AHCA, paid $322,222 for Juan Villa’s medical care after Villa was injured in an accident. Villa settled with an alleged tortfeasor for $1 million. AHCA calculated the presumptively appropriate amount of its lien at $321,720 and asserted a lien in that amount against Villa’s settlement. An administrative law judge affirmed AHCA’s lien amount. The First District Court of Appeal affirmed, concluding that both Florida law and the federal Medicaid Act allow AHCA to secure reimbursement for its Medicaid expenses from the portions of Villa’s third-party settlement recovery allocated to both past and future expenses. The Supreme Court quashed the decision below, holding that the federal Medicaid Act prohibits AHCA from placing a lien on the future medical expenses portions of a Medicaid beneficiary’s third-party tort recovery to satisfy its Medicaid lien. View "Giraldo v. Agency for Health Care Administration" on Justia Law

The Supreme Court affirmed the denial of Petitioner’s motion filed pursuant to Fla. R. Crim. P. 3.851 seeking relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and the Supreme Court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016).Petitioner was sentenced to death following a jury’s unanimous recommendation for death. Petitioner’s death sentence became final in 1998. The Supreme Court held that Hurst does not apply retroactively to Petitioner’s sentence of death, and therefore, the circuit court did not err in denying relief. View "Jimenez v. State" on Justia Law

The biological father has standing to rebut the common law presumption that the mother’s husband is the legal father of a child born to an intact marriage - or the “presumption of legitimacy” - when he has “manifested a substantial and continuing concern” for the welfare of the child. **See Kendrick v. Everheart, 390 So. 2d 53, 61 (Fla. 1980).The biological father (Father) of a child filed a petition to establish paternity, child support, and timesharing. Mother moved to dismiss the action, arguing that it was barred by the common law presumption of legitimacy because she was married at the time of the child’s birth and remained married. The circuit court concluded that it was constrained by Fourth District precedent to dismiss the petition as a matter of law. The Fourth District reversed, concluding that the presumption of legitimacy should not be applied to bar this action. The Supreme Court affirmed, holding the the presumption of legitimacy does not create an absolute bar to an action by a biological father to establish parental rights when the child’s mother was married at the time of the child’s birth and both she and her husband object to the action. View "Simmonds v. Perkins" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Appellant’s motion filed pursuant to Fla. R. Crim. P. 3.851 seeking relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and the Supreme Court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016).Appellant was sentenced to death following a jury’s recommendation for death by a vote of eight to four. Appellant’s death sentence became final in 1985. The Supreme Court held that Hurst did not apply retroactively to Appellant’s sentence of death, and therefore, the circuit court properly denied Appellant’s motion. View "Doyle v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Appellant’s motion filed pursuant to Fla. R. Crim. P. 3.851 seeking relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and the Supreme Court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016).Appellant was sentenced to death following a jury’s recommendation for death by a vote of ten to two. Appellant’s death sentence became final in 1992. The Supreme Court held that Hurst did not apply retroactively to Appellant’s sentence of death, and therefore, the circuit court properly denied Appellant’s motion. View "Owen v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Appellant’s motion filed pursuant to Fla. R. Crim. P. 3.851 seeking relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and the Supreme Court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016).Appellant was sentenced to death following a jury’s unanimous recommendation for death. The death sentence was reversed and, on remand, the trial court again sentenced Appellant to death. Appellant’s death sentence became final in 1996. The Supreme Court held that Hurst did not apply retroactively to Appellant’s sentence of death, and therefore, the circuit court properly denied Appellant’s motion. View "Dailey v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the postconviction court’s denial of Eric Kurt Patrick’s motion for postconviction relief filed under Fla. R. Crim. P. 3.851 and granted Patrick’s petition for writ of habeas corpus, which raised a valid claim under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016).In 2009, Patrick was convicted of kidnapping, robbery, and first-degree murder. Patrick’s jury recommended a death sentence by a vote of seven to five. The trial court followed the jury’s recommendation. The Supreme Court affirmed. Thereafter, Patrick filed his motion for postconviction relief and then amended his motion to add a Hurst v. Florida claim. The postconviction court denied the motion in its entirety. As to the Hurst v. Florida claim, the postconviction court noted that the Supreme Court had not yet determined whether the holding would have retroactive effect. Patrick appealed and filed a petition for writ of habeas corpus, requesting relief under Hurst v. Florida and Hurst. The Supreme Court vacated Patrick’s death sentence and granted Patrick a new penalty phase under Hurst v. Florida and Hurst in accordance with his petition for writ of habeas corpus, holding that the Hurst error in Patrick’s sentencing was not harmless beyond a reasonable doubt. View "Patrick v. State" on Justia Law

The Supreme Court disapproved the decision of the First District Court of Appeal in Snow v. State, 157 So. 3d 559 (Fla. 1st DCA 2015) on the issue of whether a trial court is required to pronounce orally each condition of “sex offender probation” contained in Fla. Stat. 948.30 when the defendant is not convicted of one of the section’s enumerated offenses.Petitioner was convicted of sex offenses, and the trial court imposed fifteen years of “sex offender probation.” Petitioner later moved to strike the section 948.30 conditions of probation that were included in the written order of sex offender probation on the ground that they constituted an illegal sentence because they were neither mandatory under the statute nor orally pronounced at sentencing. The trial court denied Petitioner’s request. The Fourth District affirmed. The Supreme Court affirmed, holding that due process was satisfied under the circumstances of this case. View "Levandoski v. State" on Justia Law