Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed the circuit court’s order denying William H. Kelley’s motion filed under Fla. R. Crim. P. 3.851, holding that Kelley 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). Kelley was sentenced to death following a jury’s recommendation for death by a vote of eight to three. Kelley’s sentence of death became final in 1986. The Supreme Court held that Hurst did not apply retroactively to Kelley’s sentence of death and thus affirmed the denial of Kelley’s motion. View "Kelley v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Charles William Finney’s motion filed under Fla. R. Crim. P. 3.851, holding that Finney 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). Finney was sentenced to death following a jury’s recommendation for death by a vote of nine to three. Finney’s sentence of death became final in 1996. The Supreme Court held that Hurst did not apply retroactively to Finney’s sentence of death and thus affirmed the denial of Finney’s motion. View "Finney v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Kenneth Hartley’s motion filed under Fla. R. Crim. P. 3.851, holding that Hartley 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). Hartley was sentenced to death following a jury’s recommendation for death by a vote of nine to three. Finney’s sentence of death became final in 1997. The Supreme Court held that Hurst did not apply retroactively to Hartley’s sentence of death and thus affirmed the denial of Hartley’s motion. View "Hartley v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Richard Harold Anderson’s motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Anderson 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). Anderson was sentenced to death following a jury’s recommendation for death by a vote of eleven to one. Anderson’s sentence of death became final in 1991. The Supreme Court held that Hurst did not apply retroactively to Anderson’s sentence of death and thus affirmed the denial of Anderson’s motion. View "Anderson v. State" on Justia Law

In this case before the Supreme Court for review of a question of law certified by the United States Court of Appeals for the Eleventh Circuit, the Supreme Court answered that post-judgment discovery for the purpose of collecting a federal money judgment issued by a federal court in Florida is permitted for a period of twenty years from the date the judgment was entered.In this case, a federal district court in Florida entered a judgment awarding Judgment Creditors money damages against Judgment Debtor. Judgment Creditors filed a motion requesting an order compelling Judgment Debtor to complete a fact information sheet. The district court denied the motion, citing Balfour Beatty Bahamas, Ltd. v. Bush, 170 F.3d 1048, 1051 (11th Cir. 1999), which provides that post-judgment discovery aimed at collecting a money judgment issued by a Florida federal court is governed by the five-year limitations period in Fla. Stat. 95.11(2)(a). The Supreme Court concluded that the Fourth District’s holding in Burshan v. National Union Fire Insurance Co., 805 So. 2d 835 (Fla. 4th DCA 2001) governed, holding that collection activity on a federal judgment is not got governed but section 95.11(2)(a) but, instead, is permitted for the twenty-year life of the judgment. View "Salinas v. Ramsey" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Lenard James Philmore’s successive motion for postconviction relief under 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 this court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Philmore was sentenced to death following a jury’s unanimous recommendation for death. Philmore’s sentence of death became final on October 7, 2002. The postconviction court found that Hurst applied retroactively to Philmore’s sentence of death but that any Hurst error was harmless. The Supreme Court affirmed, holding that the Hurst error in Philmore’s case was harmless beyond a reasonable doubt and that Philmore was not entitled to relief on his other claims. View "Philmore v. State" on Justia Law

The Supreme Court dismissed Petitioner’s pro se petition for writ of habeas corpus, the thirty-ninth pro se petition or notice he had filed with the court since 2006, and found that Petitioner has abused the court’s limited judicial resources.After dismissing Petitioner’s habeas petition, the court ordered Petitioner to show cause why he should not be barred from filing further pro se documents in the court. Petitioner did not respond to the court’s order. Therefore, based on Petitioner’s extensive history of meritless pro se filings in the court, the Supreme Court directed the clerk of the court to reject any future pleadings or requests for relief submitted by Petitioner concerning a certain case unless such filings were signed by a member in good standing of the Florida Bar. Additionally, the court found the petition filed in this case was a frivolous proceeding filed by a state prisoner. View "Kendrick v. Jones" on Justia Law

The Supreme Court’s decision in Melbourne v. State, 679 So. 2d 759 (Fla. 1996), does not require a trial court to adhere strictly to the procedure as outlined in Melbourne and its progeny.Defendant was convicted of attempted first-degree murder and other offenses and sentenced to four concurrent twenty-five year terms of imprisonment. Defendant appealed, challenging the trial court’s ruling on his objections to the State’s exercise of two peremptory challenges of African-American venire persons. The Second District concluded that Defendant failed to preserve his claim. The Supreme Court approved the decision of the Second District but not its analysis, holding (1) in the context of challenges to the use of a peremptory strike, the holding of Melbourne is reaffirmed, but when, as here, the Melbourne inquiry is incomplete or proceeds out of order, the reviewing court should focus on the opportunity provided to the opponent of the strike to be heard and make argument; and (2) Defendant preserved his challenge for appellate review, but the trial court did not err in overruling his objections. View "Spencer v. State" on Justia Law

Defendant, who was serving a forty-year sentence for a nonhomicide crime that he committed when he was a juvenile, was entitled to be resentenced under the juvenile sentencing provisions of chapter 2014-220, Laws of Florida.Defendant was fifteen years old when he committed the crime of attempted first-degree murder. Because Fla. Stat. 775.087 applied, the trial court classified the offense as a life felony and sentenced Defendant to life without parole. After the United States Supreme Court’s decision in Graham v. Florida, 560 U.S. 48 (2010), Defendant filed a motion to correct illegal sentence, which the trial court granted. Upon resentencing, a successor trial judge sentenced defendant to forty years’ imprisonment with a twenty-five year minimum mandatory sentence. The Second District Court of Appeal affirmed. The Supreme Court held that Defendant, who was resentenced after Graham but before the Legislature passed chapter 2014-220, was entitled to resentencing where his sentence did not provide him an opportunity to obtain early release based on a demonstration of maturity and rehabilitation before the expiration of the imposed term. View "Lee v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying William Gregory Thomas’s motion filed under Fla. R. Crim. P. 3.851, holding that Thomas 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). Thomas was sentenced to death following a jury’s recommendation for death by a vote of eleven to one. Thomas’s sentence of death became final in 1997. The Supreme Court held that Hurst did not apply retroactively to Thomas’s sentence of death and thus affirmed the denial of Thomas’s motion. View "Thomas v. State" on Justia Law