Justia Florida Supreme Court Opinion Summaries

A defendant who claims that the offense as charged in the information is barred by the statute of limitations must raise the issue in the trial court in order to preserve the issue for direct appeal.On appeal from his convictions for burglary of a dwelling with the intent to commit sexual battery or robbery and sexual battery committed with possession of a firearm, offenses that occurred more than twenty years earlier, Defendant argued for the first time that the prosecution for armed burglary was subject to the four-year limitations period provided in Fla. Stat. 775.15(2)(a). The Third District Court of Appeal certified a question of law to the Supreme Court as a question of great public importance. The Supreme Court answered by holding that a defendant must raise a claim that conviction of a charged offense violates the statute of limitations in the trial court to preserve the issue for direct appeal. View "State v. Smith" on Justia Law

The Supreme Court affirmed the postconviction court’s order denying Appellant relief on his successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851 in which Appellant sought to vacate his death sentence pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016).Appellant, an inmate at Tomoka Correctional Institution, was convicted and sentenced to death for the first-degree murder of a correctional officer. This appeal concerned Appellant’s first successive motion for postconviction relief raising claims under Hurst. The Supreme Court affirmed the denial of relief, holding (1) Appellant’s argument that the stricken cold, calculate, and premeditated aggravator in his case was sufficient to receive Hurst relief failed because any error was harmless beyond a reasonable doubt; (2) Appellant’s subclaims failed on the merits or were duplicative; (3) Appellant’s sentence did not violate the Eighth Amendment; and (4) Appellant’s claim that he was denied his right to a proper indictment because the grand jury indictment in his case did not list the aggravators failed. View "Hall v. State" on Justia Law

The Supreme Court affirmed the trial court’s order summarily denying Appellant’s renewed motion for a determination of intellectual disability as a bar to execution, filed under Fla. R. Crim. P. 3.203 and Fla. Stat. 921.137, holding that Appellant could not have met his burden to demonstrate that he was intellectually disabled.Appellant pleaded guilty to first-degree felony murder and was sentenced to death. In 2015, in the wake of Hall v. Florida, 134 S. Ct. 1986 (2014), Appellant filed a renewed motion for a determination of intellectual disability as a bar to execution. After a hearing, the trial court concluded that Appellant failed to prove that he was intellectually disabled because none of the three IQ scores he had presented fell within the standard error of measurement of IQ tests. The Supreme Court affirmed, holding that because Appellant failed to meet the significantly subaverage intellectual functioning prong of he intellectual disability standard, he was not entitled to relief. View "Quince v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s order summarily denying Appellant’s first successive postconviction motion filed under Fla. R. Crim. P. 3.851.Appellant was convicted of first-degree murder, kidnapping, robbery, sexual battery, and burglary of a conveyance with assault. The trial court sentenced Appellant to death following a unanimous jury recommendation for death. In the instant successive postconviction motion, Appellant claimed that he was entitled to relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court affirmed the postconviction court’s denial of relief, holding that the Hurst error in this case was harmless beyond a reasonable doubt. View "Johnston v. State" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellant’s motion to vacate sentences of death under Fla. R. Crim. P. 3.851. The jury in Appellant’s case unanimously recommended death. In this successive postconviction motion, Appellant argued that his death sentences violated the Sixth Amendment in light of Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), and Hurst v. Florida, 136 S. Ct. 616 (2016) and that his death sentences violated the Eighth Amendment under Caldwell v. Mississippi, 472 U.S. 320 (1985), and must be vacated in light of Hurst, Hurst v. Florida, and Perry v. State, 210 So. 3d 630 (Fla. 2016). The circuit court denied relief. The Supreme Court affirmed, holding (1) the Hurst error in this case was harmless beyond a reasonable doubt; (2) Hurst-induced Caldwell claims against the standard jury instruction do not provide an avenue for Hurst relief; and (3) the circuit court properly denied Appellant’s Eighth Amendment Caldwell claim. View "Reynolds v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s order denying Appellant’s motion to vacate judgments of conviction, including his conviction for first-degree murder, and his sentence of death under Fla. R. Crim. P. 3.851.Following a jury's unanimous recommendation for death, the trial court sentenced Appellant to death. The Supreme Court affirmed. In this successive postconviction motion, Appellant claimed that he was entitled to relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). The postconviction court denied relief. The Supreme Court affirmed, holding that Hurst was applicable in Appellant’s case, but the Hurst error here was harmless beyond a reasonable doubt. View "Tanzi v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s order vacating Appellee’s sentence of death and granting Appellee a new penalty phase, holding that the Hurst error in Appellee’s case was not harmless beyond a reasonable doubt.Appellee was convicted of first-degree murder, kidnapping, and capital sexual battery and sentenced to death. The jury recommended a death sentence by a vote of ten to two. The Supreme Court affirmed the convictions and sentence. Appellee’s death sentence became final in 2011. After the issuance of Hurst v. Florida, 136 S. Ct. 616 (2016), Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), and its progeny, Appellee filed a successive motion to vacate death sentence. The postconviction court granted the motion with regard to the claim that Appellee was entitled to a new penalty phase. The Supreme Court affirmed, holding that because the jury did not make the requisite factual findings under Hurst and did not unanimously recommend a sentence of death, the Hurst error in Appellee’s case was not harmless beyond a reasonable doubt. View "State v. Smith" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Appellant’s successive motion for postconviction relief seeking relief based on Hurst v. Florida, 136 S. Ct. 616 (2016), Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), and Perry v. State, 210 So. 3d 630 (Fla. 2016).Appellant was convicted of first-degree murder and kidnapping with intent to commit or facilitate the commission of a homicide. The jury unanimously recommended death. On direct appeal, the Supreme Court affirmed Appellant’s first-degree murder conviction but reversed the judgment of guilt of kidnapping and remanded for entry of judgment for false imprisonment. Appellant’s sentence of death became final in 2005. On appeal from the denial of his postconviction motion, Appellant argued that the Hurst error in his case was not harmless beyond a reasonable doubt even where the jury unanimously recommended death. The Supreme Court disagreed, holding that the Hurst error in Appellant’s case was harmless beyond a reasonable doubt. View "Crain v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Appellant’s successive postconviction motion to vacate a sentence of death under Fla. R. Crim. P. 3.851. In his successive motion, Appellant claimed that his death sentence violated the Sixth Amendment in light of Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), and Hurst v. Florida, 136 S. Ct. 616 (2016) and violated the Eighth Amendment under Caldwell v. Mississippi, 472 U.S. 320 (1985). The Supreme Court affirmed the circuit court’s order summarily denying Appellant’s successive motion for postconviction relief, holding (1) any Hurst error in this case was harmless beyond a reasonable doubt; and (2) Appellant’s Caldwell claim was procedurally barred because it was raised and rejected on direct appeal. View "Taylor v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order summarily denying Defendant’s first successive motion for postconviction relief, holding that any Hurst error in this case was harmless beyond a reasonable doubt.In 1998, a jury convicted Defendant of two counts of first-degree murder. The jury unanimously recommended the death sentence for each murder by a vote of twelve to zero. The Supreme Court affirmed the convictions and death sentences on direct appeal. In 2017, Defendant filed his first successive postconviction motion in which he raised numerous claims in light of Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court summarily denied Defendant’s successive postconviction motion. The Supreme Court affirmed, holding that any Hurst error was harmless. View "Smithers v. State" on Justia Law