Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court denying Appellant's motions in this criminal case in which Appellant was under a death warrant, holding that Appellant was not entitled to relief.Defendant was convicted of the murders of two women and sentenced to death. The United States Supreme Court denied certiorari review in 1992. After the governor signed a death warrant for one murder and scheduled the execution for June 15, 2023 Appellant sought relief in the circuit court, without success. The Supreme Court affirmed, holding that the circuit court did not err in (1) summarily denying Defendant's fourth postconviction motion under Fla. R. Crim. P. 3.851; (2) denying Defendant's motion for competency determination; and (3) denying Defendant's motion for MRI and PET scan. The Court also denied Defendant's motion for stay of execution. View "Owen v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition for a writ of prohibition challenging the trial court's rulings in criminal cases and a separate civil case, holding that Petitioner failed to show cause why he should not be pro se barred for his repeated misuse of the Court's limited resources.Petitioner, an inmate whose most recent conviction was for possession of a controlled substance, began filing petitions in the Supreme Court in 2018 pertaining to several different criminal cases and a dependency case regarding his children. Petitioner filed the instant prohibition petition challenging the trial court's denial of a motion and seeking to dismiss the case. The Supreme Court denied the petition and directed Petitioner to show cause why he should not be barred from filing further pro se requests for relief. The Supreme Court then sanctioned Petitioner, holding that Petitioner had abused the Court's limited judicial resources. View "Hill v. State" on Justia Law

The Supreme Court denied Petitioner's petition for a writ of habeas corpus and then sanctioned him, holding that Petitioner failed to show cause why he should not be pro se barred.In 2006, Petitioner was sentenced to life imprisonment as a prison releasee reoffender on two counts of kidnapping, and the court of appeal affirmed. Since 2006, the Petitioner "engaged in a vexatious pattern of filing meritless requests for relief" in the Supreme Court pertaining to his convictions and sentences, none of which merited relief. In the instant habeas petition, Petitioner raised several claims relating to the circuit court's 2006 judgment and sentence. The Supreme Court denied the petition and directed Petitioner to show cause why he should not be barred from filing further pro se requests for relief. The Supreme Court sanctioned Petitioner as pro se barred, holding that Petitioner failed to show cause why he should not be sanctioned for his abusive conduct. View "Steiner v. Dixon" on Justia Law

The Supreme Court approved the decision of the First District Court of Appeal affirming the trial court's judgment concluding that this negligence action was untimely filed, holding that Fla. Stat. 733.710(1) extinguished the claim at issue in this case.Petitioners, who were injured in an accident by Thomas Morton, sued Morton's estate for negligently operating the car and his employer, the Lewis Bear Company (LBC), for vicarious liability under the doctrines of respondeat superior and dangerous instrumentality. The trial court ruled (1) section 733.710(1) barred Petitioners' action against the estate because they failed to file their claims within two years of Morton's death; and (2) because the Estate could not be held liable, LBC could not be held vicariously liable. The court of appeal affirmed. The Supreme Court affirmed, holding (1) because Petitioners' claims against the estate were filed beyond section 733.710(1)'s deadline and did not qualify under an exception, they were barred; and (2) the court of appeal correctly held that section 733.710(1)'s statute of non claim exonerated LBC from vicarious liability for Morton's negligence. View "Tsuji v. Fleet" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of first-degree murder but set aside and his sentences of death for each murder, holding that Defendant was deprived of his right to "have the Assistance of Counsel for his defense" when the trial court put him to an improper choice at the beginning of the penalty phase proceedings.After the jury returned guilty verdicts for both first-degree murder charges the matter proceeded to the penalty phase. The jury unanimously recommended sentences of death. After a series of Spencer hearings, the trial court sentenced Defendant to death for each murder. The Supreme Court affirmed and remanded the case for a new penalty phase, holding (1) the trial court did not commit reversible error in its evidentiary rulings during Defendant's guilt phase proceedings; (2) Defendant's convictions were supported by competent, substantial evidence; but (3) Defendant's waiver of his right to counsel during the penalty phase was not knowing, intelligent, and voluntary, and Defendant was entitled to a new sentencing hearing based on the trial court's fundamental error in forcing him to abandon counsel during that phase. View "Figueroa-Sanabria v. State" on Justia Law

The Supreme Court denied a petition filed by Petitioner Andrew H. Warren, the elected State Attorney for the Thirteenth Judicial Circuit, arguing that Governor Ron DeSantis lacked authority to issue Executive Order 22-176 suspending him on the grounds of neglect of duty and incompetence, holding that the petition is denied on the ground of unreasonable delay.Within two weeks of his suspension Petitioner sued in federal district court requesting a writ of quo warranto on the basis that the suspension order was facially insufficient under Florida law. The federal court dismissed the claim. More than six months after Governor DeSantis issued the executive order at issue Petitioner filed this petition requesting the issuance of a writ of quo warranto and, alternatively, seeking a writ of mandamus ordering the Governor to reinstate him. The Supreme Court denied the petition, holding that, under the circumstances involving "dilatory conduct" on the part of Petitioner, this Court declines to consider Petitioner's claims for relief. View "Warren v. DeSantis" on Justia Law

The Supreme Court held that Florida's offer-of-judgment statute does not impose the requirement that a party must prevail in a proceeding to be entitled to fees under the statute, and therefore, the statute is not a prevailing-party statute.Plaintiff sued R.J. Reynolds Tobacco Company seeking damages for her sister's wrongful death. Before trial, Plaintiff served Defendant with two proposals for settlement, both of which Defendant rejected. After a jury trial, the jury awarded Plaintiff $300,000 in compensatory damages and $16,000,000 in punitive damages. The court of appeal reversed the punitive damages award as excessive. Thereafter, Plaintiff sought attorney's fees based on Defendant's rejection of her offers of judgment. The Supreme Court provisionally granted the motion for reasonable attorney's fees conditioned upon the trial court's finding of entitlement and determination of amount, holding that the offer-of-judgment statute is not a prevailing-party statute. View "Coates v. R.J. Reynolds Tobacco Co." on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding Defendant sane to be executed, holding that the record contained competent, substantial evidence to support the circuit court's determination that Defendant was sane to be executed.After considering all the evidence, the circuit court concluded that Defendant failed to establish by clear and convincing evidence that he was insane to be executed. The Supreme Court affirmed, holding that the circuit court (1) did not err in finding Defendant sane to be executed; and (2) did not abuse its discretion in denying Defendant's motion for a continuance. View "Owen v. State" on Justia Law

The Supreme Court approved the decision of the court of appeal affirming the trial court's denial of Defendant's motion to suppress eyewitness identifications resulting from an out-of-court police procedure, holding that the proper standard of review is abuse of discretion review and that the court of appeal correctly analyzed the merits under that standard.In denying Defendant's motion to suppress, the court of appeal applied the abuse of discretion standard of review to the trial court's ruling on the out-of-court identification by the eyewitness. On appeal, the court of appeal affirmed "[d]ue to the abuse of discretion standard of review." The Supreme Court approved the decision below, holding (1) abuse of discretion review is the proper standard; and (2) the trial court did not abuse its discretion in admitting the out-of-court identification. View "Alahad v. State" on Justia Law

The Supreme Court dismissed Petitioner's pro se petition for writ of mandamus and sanctioned him for his repeated misuse of the judicial system's resources, holding that Petitioner's petition was frivolous.Petitioner was convicted of robbery with a weapon and trafficking in stolen property and sentenced to life in prison as a Prison Releasee Reoffender (PRR). The Third District Court of Appeal reversed Petitioner's PRR sentence and remanded the case with instructions to impose a "guideline sentence." Since then, Petitioner filed various filings related to his convictions and sentences, including this pro se mandamus petition. The Supreme Court dismissed the mandamus petition and directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner unless such filings are signed by a member in good standing of The Florida Bar, holding that Petitioner's petition was frivolous and that Petitioner demonstrated a pattern of vexatious filing of meritless pro se requests for relief. View "Foley v. State" on Justia Law