Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed the circuit court’s order summarily denying Appellant’s first successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that any Hurst error in this case was harmless beyond a reasonable doubt.In 2000, a jury convicted Appellant of first-degree murder and sexual battery upon a person twelve years of age or older with use of a deadly weapon. The jury unanimously recommended the death sentence by a vote of twelve to zero. The Supreme Court affirmed Appellant’s convictions and death sentence on direct appeal. In 2016, Appellant filed his first successive postconviction motion arguing that he was entitled to relief based on Hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). The circuit court summarily denied Appellant’s successive postconviction motion. The Supreme Court affirmed, holding that any Hurst error in this case was harmless beyond a reasonable doubt. View "Grim v. State" on Justia Law

The Supreme Court affirmed the orders of the circuit court denying Ronnie Johnson’s motions filed under 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 this Court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Johnson was sentenced to death for one murder conviction following a jury’s recommendation for death by a vote of seven to five. Johnson was also sentenced to death for a second murder following a jury’s recommendation for death by a vote of nine to three. Both of Johnson’s death sentences became final in 1998. In affirming the denial of Johnson’s motions, the Supreme Court held that Hurst did not apply retroactively to Johnson’s sentences of death. View "Johnson v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Appellant’s motion filed under Fla. R. Crim. P. 3.851 in which Appellant sought relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and this 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, and his sentence of death became final in 2001. In affirming, the Supreme Court held that Hurst did not apply retroactively to Appellant’s sentence of death and, accordingly, affirmed the denial of Appellant’s motion. View "Gonzalez v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Appellant’s motion filed under Fla. R. Crim. P. 3.851 in which Appellant sought relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and this 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, and his sentence of death became final in 2001. In affirming, the Supreme Court held that Hurst did not apply retroactively to Appellant’s sentence of death and, accordingly, affirmed the denial of Appellant’s motion. View "Gonzalez v. State" on Justia Law

The Supreme Court denied the petition of Petitioner seeking to invoke the Court’s discretionary jurisdiction based on express and direct conflict. Further, due to Petitioner’s numerous meritless and inappropriate filings in the Supreme Court pertaining to his foreclosure proceedings in the circuit court during the pendency of his petition for jurisdiction in this case, the Court sanctioned Petitioner by barring him from filing in the Court any future pro se pleadings, motions, or other requests for relief pertaining to his foreclosure proceedings. Counsel may file on Petitioner’s behalf if counsel determines that the proceeding may have merit and can be brought in good faith. View "Rivas v. Bank of New York Mellon" on Justia Law

In this medical malpractice action, the trial court did not abuse its discretion when it allowed Monica Gutierrez’s treating physicians to testify during trial as to their diagnostic opinions and permitted Monica and her parents (collectively, “Petitioners”) to present rebuttal testimony from a second pathology expert. Further, any prejudice attributable to comments made during Petitioners’ closing argument did not merit a new trial.Petitioners alleged that Dr. Jose Vargas negligently failed to diagnose Monica with a chronic kidney disease, which severely damaged her kidneys and forced her to undergo a kidney transplant. After a second trial, the court entered a final judgment award of over $4 million for Petitioners. The Third District Court of Appeal reversed and remanded for a new trial, concluding that Petitioners violated the “one expert per specialty” rule and materially misrepresented the evidence during closing arguments. The Supreme Court quashed the decision of the Third District, holding (1) admitting the testimony of Monica’s treating physicians was proper because they testified as Monica’s treating physicians, not expert witnesses; (2) a second pathology expert properly testified in rebuttal; and (3) a single improper comment by Petitioners’ counsel did not require a new trial. View "Gutierrez v. Vargas" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant’s motion to vacate a judgment of conviction of first-degree murder and a sentence of death filed under Fla. R. Crim. P. 3.851. In his successive postconviction motion, Appellant, who was convicted of four counts of first-degree murder with a firearm, sought relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). In its answer, the State asserted that the motion should be summarily denied because Appellant waived his rights to Hurst relief when he waived his penalty phase jury. The circuit court summarily denied the motion. The Supreme Court affirmed, holding that Appellant was not entitled to postconviction relief in light of this Court’s decisions in Brant v. State, 197 So. 3d 1051 (Fla. 2016), and Mullens v. State, 197 So. 3d 16 (Fla. 2016). View "Hutchinson v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions for murder and kidnapping but vacated his sentence of death and remanded for the imposition of a life sentence without eligibility for parole based on Defendant’s performance of his part of his agreement with the State. In the agreement, the State agreed not to seek the death penalty if Defendant agreed to lead investigators to the body. After the body was discovered, the State filed its notice of intent to seek the death penalty. The trial court subsequently denied Defendant’s motion to enforce the agreement. On appeal, Defendant argued that the trial court erred in denying his motion to prohibit the State from seeking the death penalty. The Supreme Court agreed, holding that once Defendant performed his end of the bargain with the State, the State was obligated to uphold its end of the agreement. As to Defendant’s remaining arguments concerning his conviction, the Supreme Court denied relief. The Supreme Court remanded the case with instructions for the trial court to reduce Defendant’s death sentence to life imprisonment without the possibility of parole. View "Johnson v. State" on Justia Law

The Supreme Court found that Petitioner failed to show cause why he should not be barred from filing further pro se filings in this court and directed the clerk of the court to reject any future pleadings or other requests for relief submitted by Petitioner unless such filings were signed by a member in good standing of The Florida Bar.In 2006, Petitioner was convicted of several criminal offenses and sentenced to thirty years’ imprisonment. The court of appeal affirmed. Since then, Petitioner demonstrated a pattern of vexatious filing of meritless pro se requests for relief in the Supreme Court. The Supreme Court dismissed the instant petition for writ of habeas corpus filed in 2017 as unauthorized pursuant to Baker v. State, 878 So. 2d 1236 (Fla. 2004), and expressly retained jurisdiction to consider the imposition of sanctions. The court subsequently determined that Petitioner had abused this court’s limited judicial resources, sanctioned Petitioner, and found the petition filed in this case was a frivolous proceeding filed by a state prisoner. View "Hickmon v. Jones" on Justia Law

The Supreme Court affirmed the trial court’s denial of Appellant’s third successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851, holding that the trial court’s failure to hold a case status conference was harmless error and that no evidentiary hearing was required because the motion was legally insufficient on its face and refuted by the record. Further, the trial court did not err by summarily denying Appellant’s claim based on newly discovered evidence and Brady v. Maryland, 373 U.S. 83 (1963). View "Sochor v. State" on Justia Law