Justia Florida Supreme Court Opinion Summaries

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.Appellant pleaded guilty to first-degree murder and burglary of a dwelling and was sentenced to death. Appellant filed a successive motion for postconviction relief seeking to vacate his death sentence on the ground that he was intellectually disabled and therefore ineligible for the death penalty. The trial court denied the motion. After the United States Supreme Court issued its decision in Hall v. Florida, 572 U.S. __ (2014), Appellant filed a renewed motion for a determination of intellectual disability as a bar to execution. The trial court concluded that Appellant failed to prove that he was intellectually disabled. The Supreme Court affirmed, holding that Appellant was not entitled to relief on any of his claims. View "Quince v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree murder but vacated his death sentence and remanded for a new penalty phase. Defendant was sentenced to death after a jury recommended the death penalty by a vote of ten to two. On appeal, the Supreme Court held (1) the trial court did not err by allowing Defendant’s co-defendant to testify that he and Defendant were involved in the separate murder; (2) substantial evidence supported the conviction; but (3) the jury’s nonunanimous recommendation of death violated Hurst v. State, 202 So. 3d 40 (Fla. 2016), and the error was not harmless beyond a reasonable doubt. View "Kirkman v. State" on Justia Law

The Supreme Court approved the First District Court of Appeal’s holding in Hall v. Lopez, 213 So. 3d 1003 (Fla. 1st DCA 2017), that Fla. Stat. 57.105 does not prohibit awarding attorney’s fees in dating, repeat, and sexual violence injunction proceedings under Fla. Stat. 784.046.Nicole Lopez filed a petition for injunction for protection against repeat and dating violence under section 784.046 against Sean Hall and received a temporary injunction. Hall later moved for attorney’s fees and sanctions under section 57.105, claiming that Lopez perjured herself in her petitions. Thereafter, Lopez voluntarily dismissed her action. The trial court denied Hall’s motion for attorney’s fees, concluding that section 784.046 does not authorize an award of section 57.105 attorney’s fees on any basis. The First District reversed. The Supreme Court affirmed, holding that section 57.105 may be applied to repeat, dating, and sexual violence injunction proceedings under section 784.046. View "Lopez v. Hall" on Justia Law

The Supreme Court affirmed Defendant’s conviction of first-degree murder but vacated his sentence of death and remanded for a new penalty phase. The jury in this case recommended death by a vote of ten to two. The Supreme Court held (1) the trial court did not err when it granted the State’s motion for reconsideration of Defendant’s motion for change of venue; (2) the trial court did not err in overruling Defendant’s objection to the admission of his spontaneous statements while under observation in jail; (3) assuming that two of the prosecutor’s statements were improper, neither of these issues individually amounted to fundamental error, and the cumulative effect of these errors did not deprive Defendant of a fair trial; (4) substantial evidence supported Defendant’s conviction; but (5) the Hurst error in Defendant’s sentencing was not harmless beyond a reasonable doubt. View "Morris v. State" on Justia Law

The Supreme Court approved the First District Court of Appeal’s decision ruling that the Dangerous Sexual Felony Offender Act (the DSFO Act) authorizes a mandatory minimum life sentence regardless of the statutory maximum for the crimes.The First District certified conflict with Wilkerson v. State, 143 So. 3d 462 (Fla. 5th DCA 2014), in which the First District Court of Appeal concluded that, when the statutory maximum for a particular crimes is less than twenty-five years, the DSFO authorizes a trial court to impose only a mandatory minimum term of twenty-five years’ imprisonment. In the instant case, the trial court sentenced Defendant under the DSFO Act to a mandatory minimum life sentence for a second-degree felony that generally carried a fifteen-year statutory maximum. The Supreme Court approved the First District’s decision in Williams and disapproved the Fifth District’s decision in Wilkerson to the extent it was inconsistent with this opinion, holding that, in upholding the sentence int his case, the First District interpreted the “25 to life” provision in the DSFO Act consistently with Mendenhall v. State, 48 So, 3d 740 (Fla. 2010), which controls this case. View "Williams v. State" on Justia Law

A petition for a writ of habeas corpus is the proper vehicle by which to seek release from close management, which the Florida Administrative Code defines as “the confinement of an inmate apart from the general population.”Defendant, an inmate, was reassigned to a “close management” cousin classification. The Department of Corrections upheld the decision. Defendant then filed a petition for a writ of habeas corpus, which the circuit court denied. On appeal, the First District Court of Appeal announced its decision to “recede from prior decisions…allow[ing] [c]lose [m]anagement decisions to be challenged by writ of habeas corpus,” concluding that the appropriate vehicle for challenges to close management assignments was a petition for writ of mandamus. The Supreme Court quashed the decision of the First District, holding that a petition for a writ of habeas corpus remains the correct mechanism by which to challenge a reassignment. View "Banks v. Jones" on Justia Law

Defendant was entitled to a new penalty phase proceeding pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016) and Mosley v. State, 209 So. 3d 1248 (Fla. 2016) and based on his claim of ineffective assistance of penalty phase counsel.Defendant was convicted of first-degree murder and other crimes. The jury recommended a sentence of death for the murder by a vote of eleven to one. The trial court imposed a sentence of death. Defendant later filed a motion to vacate judgment of conviction and sentence pursuant to Fla. R. Crim. P. 3.851. The postconvcition denied all claims, concluding that penalty phase counsel was deficient but that Defendant was not prejudiced as a result. Defendant appealed and filed a petition for writ of habeas corpus seeking relief pursuant to Hurst v. Florida, 577 U.S. __ (2016). The Supreme Court affirmed the denial of postconvcition relief but granted the petition for writ of habeas corpus, vacated Defendant’s death sentence, and remanded, holding (1) trial counsel was deficient for failing to discover paternal neglect, paternal abuse, and the extent of paternal substance abuse, and the deficiency was prejudicial; and (2) the failure to require a unanimous verdict regarding the sentence of death was not harmless. View "Ellerbee v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions for first-degree murder and other crimes but vacated his death sentence and remanded for a new penalty phase. After the penalty phase, the jury voted nine to three to recommend a sentence of death. The trial judge followed the jury’s recommendation. On appeal, Defendant raised seven allegations of error regarding guilt phase issues. The Supreme Court held that none of the issues warranted relief and that the evidence was sufficient to support Defendant’s first-degree murder conviction. The court, however, concluded that Defendant’s death sentence violated Hurst v. Florida, 577 U.S. __ (2016) and that the error in Defendant’s sentencing was not harmless beyond a reasonable doubt. View "Lebron v. State" on Justia Law

The Supreme Court dismissed the petition of the League of Women Voters of Florida for a writ of quo warranto, holding that the issue presented was not ripe for consideration.The League asked the Supreme Court to issue a writ of quo warranto against Governor Rick Scott to prohibit him from filling judicial vacancies on Florida’s appellate courts due to terms expiring in January 2019. Although Governor Scott announced his intent to appoint replacements for three justices of the Supreme Court, no appointments at the time of this opinion had been made. The Supreme Court held that the matter the League sought to have resolved was not ripe, and therefore, the Supreme Court lacked jurisdiction to determine whether quo warrants relief was warranted. View "League of Women Voters of Florida v. Scott" on Justia Law

The notice and repair process set forth in Fla. Stat. 558 is a “suit” within the meaning of the commercial general liability policy issued in this case by Crum & Forster Speciality Insurance Company (C&F) to Altman Contractors, Inc.According to the policy, C&F had a duty to defend Altman in any “suit” arising from the construction of a condominium. Altman claimed that this duty to defend was invoked when the property owner served it with several notices under chapter 558 cumulatively claiming over 800 construction defects in the project. Altman filed a declaratory judgment action seeking a declaration that C&F owed a duty to defend and to indemnify it under the policy. The federal district court granted summary judgment for C&F, concluding that nothing about the chapter 558 process satisfied the definition of “civil proceeding.” Altman appealed, and the United States Circuit Court of Appeals for the Eleventh Circuit certified the legal issue to the Supreme Court. The Supreme Court answered the certified question in the affirmative because the chapter 558 presuit process is an “alternative dispute resolution proceeding” as included in the policy’s definition of “suit.” View "Altman Contractors, Inc. v. Crum & Forster Specialty Insurance Co." on Justia Law