Justia Florida Supreme Court Opinion Summaries

Juvenile offenders’ sentences of life with the possibility of parole after twenty-five years do not violate the Eighth Amendment of the United States Constitution as set forth in Graham v. Florida, 560 U.S. 48 (2010), Miller v. Alabama, 567 U.S. 460 (2012), and Virginia v. LeBlanc, 137 S. Ct. 1726 (2017), and therefore, such juvenile offenders are not entitled to resentencing under Fla. Stat. 921.1402.Defendant was convicted of first-degree premeditated murder and armed robbery, crimes he committed when he was sixteen years old. Defendant was sentenced to life imprisonment with the possibility of parole after twenty-five years for the murder conviction. Defendant later filed a motion for postconviction relief pursuant to Fla. R. Crim. P. 3.850, asserting that he was entitled to relief under Miller. The trial court denied the motion, concluding that Miller was inapplicable because Defendant had the opportunity for release on parole. The court of appeal reversed, concluding that Atwell v. State, 197 So. 3d 1040 (Fla. 2016), required resentencing even where the offender may later obtain parole. The Supreme Court quashed the decision below, holding that juvenile offenders’ sentences of life with the possibility of parole after twenty-five years under Florida’s parole system do not violate Graham, and therefore, such offenders are not entitled to resentencing. View "State v. Michel" on Justia Law

Upon revocation of a youthful offender’s probation for a substantive violation, the trial court is authorized to either impose another youthful offender sentence, with no minimum mandatory, or to impose an adult Criminal Punishment Code sentence requiring imposition of any minimum mandatory term of incarceration associated with the offense of conviction.Defendant was eighteen years old when he pleaded guilty to robbery with a firearm, which carried a ten-year minimum mandatory sentence. The trial court sentenced Defendant as a youthful offender under the Florida Youthful Offender Act to four years in prison and two years of probation. After Defendant violated his probation the trial court revoked his probation and sentenced him on the underlying offense of robbery with a firearm to fifteen years in prison, with a ten-year minimum mandatory sentence. The court of appeal affirmed. The Supreme Court quashed the decision below and remanded the case for resentencing, holding that where a defendant is initially sentenced to probation or community control as a youthful offender and the trial court later revokes supervision for a substantive violation and imposes a sentence above the youthful offender cap under Fla. Stat. 958.14 and 948.06(2), the court is required to impose a minimum mandatory sentence that would have originally applied to the offense. View "Eustache v. State" on Justia Law

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