Justia Florida Supreme Court Opinion Summaries

The Supreme Court quashed the decision of the First District Court of Appeal in Roberts v. State, 168 So. 3d 252 (Fla. 1st DCA 2015), to the extent it was inconsistent with the Supreme Court’s decision in Walton v. State, 208 So. 3d 60 (Fla. 2016), holding that Defendant was entitled to a new trial pursuant to Walton.A jury found Defendant guilty of attempted second-degree murder and other offenses. On appeal, Defendant argued that the trial court fundamentally erred by failing to instruct the jury on the necessarily lesser included offense of attempted manslaughter by act. The First District rejected Defendant’s claims and affirmed her convictions and sentences. The Supreme Court quashed the decision below, holding that, like Walton, the trial court’s failure to give the attempted manslaughter by act instruction constituted fundamental error. The court remanded the case to the First District for further proceedings. View "Roberts v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Pablo San Martin’s motion filed under Fla. R. Crim. P. 3.851, holding that San Martin was not entitled to 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). San Martin was sentenced to death following a jury’s unanimous recommendation for death by a vote of nine to three. San Martin’s sentence of death became final in 1998. The Supreme Court held that Hurst did not apply retroactively to San Martin’s sentence of death and, accordingly, affirmed the denial of San Martin’s motion. View "San Martin v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Bobby Allen Raleigh’s motion filed under Fla. R. Crim. P. 3.851, holding that Raleigh was not entitled to relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 577 U.S. ___ (2016), and this court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Raleigh was sentenced to death on two counts of first-degree murder following a jury’s unanimous recommendation for death on both counts. Raleigh’s sentence of death became final in 1998. The Supreme Court held that Hurst did not apply retroactively to Raleigh’s sentence of death and, accordingly, affirmed the denial of Raleigh’s motion. View "Raleigh v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Thomas Dewey Pope’s motion filed under Fla. R. Crim. P. 3.851, holding that Pope was not entitled to relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 577 U.S. ___ (2016), and this court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Pope was sentenced to death following a jury’s recommendation for death by a vote of nine to three. Pope’s sentence of death became final in 1984. The Supreme Court held that Hurst did not apply retroactively to Pope’s sentence of death and, accordingly, affirmed the denial of Pope’s motion. View "Pope v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Ronald Palmer Heath’s motion filed under Fla. R. Crim. P. 3.851, holding that Heath was not entitled to relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 577 U.S. ___ (2016), and this court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Heath was sentenced to death following a jury’s recommendation for death by a vote of ten to two. Heath’s sentence of death became final in 1995. The Supreme Court held that Hurst did not apply retroactively to Heath’s sentence of death and, accordingly, affirmed the denial of Heath’s motion. View "Heath v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Mark Allen Geralds’ motion filed Geralds Fla. R. Crim. P. 3.851, holding that Geralds was not entitled to relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 577 U.S. ___ (2016), and this court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Brown was sentenced to death following a jury’s unanimous recommendation for death. Geralds’ sentence of death became final in 1996. The Supreme Court held that Hurst did not apply retroactively to Geralds’ sentence of death and, accordingly, affirmed the denial of Geralds’ motion. View "Geralds v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Louis B. Gaskin’s motion filed under Fla. R. Crim. P. 3.851, holding that Gaskin was not entitled to relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 577 U.S. ___ (2016), and this court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Gaskin was sentenced to two sentences of death following a jury’s unanimous recommendation for two death sentences for two murders, both by a vote of eight to four. Gaskin’s sentence of death became final in 1993. The Supreme Court held that Hurst did not apply retroactively to Gaskin’s sentence of death and, accordingly, affirmed the denial of Gaskin’s motion. View "Gaskin v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Louis B. Gaskin’s motion filed under Fla. R. Crim. P. 3.851, holding that Gaskin was not entitled to relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 577 U.S. ___ (2016), and this court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Gaskin was sentenced to two sentences of death following a jury’s unanimous recommendation for two death sentences for two murders, both by a vote of eight to four. Gaskin’s sentence of death became final in 1993. The Supreme Court held that Hurst did not apply retroactively to Gaskin’s sentence of death and, accordingly, affirmed the denial of Gaskin’s motion. View "Gaskin v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Milford Wade Byrd’s motion filed under Fla. R. Crim. P. 3.851, holding that Byrd was not entitled to relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 577 U.S. ___ (2016), and this court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Byrd was sentenced to death following a jury’s recommendation for death. Byrd’s sentence of death became final in 1986. The Supreme Court held that Hurst did not apply retroactively to Byrd’s sentence of death and, accordingly, affirmed the denial of Byrd’s motion. View "Byrd v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Paul Anthony Brown’s motion filed under Fla. R. Crim. P. 3.851, holding that Brown was not entitled to relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 577 U.S. ___ (2016), and this court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Brown was sentenced to death following a jury’s unanimous recommendation for death. Brown’s sentence of death became final in 1999. The Supreme Court held that Hurst did not apply retroactively to Brown’s sentence of death and, accordingly, affirmed the denial of Brown’s motion. View "Brown v. State" on Justia Law