Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of first-degree premeditated and felony murder. The jury recommended the death penalty by a vote of ten to two. The trial court followed the jury’s recommendation and sentenced Defendant to death. The Supreme Court affirmed the convictions but vacated the death sentence, holding (1) the trial court did not err by admitting, for purposes of impeachment, collateral crime evidence that Defendant signed a sworn statement in which he admitted to concealing a metal shank inside his pants while in jail awaiting trial for the victim’s murder; (2) the State did not improperly comment on Defendant’s right to silence; (3) the evidence was sufficient to support Defendant’s conviction; but (4) Defendant’s death sentence violated Hurst v. State, and the Hurst error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Brookins v. State" on Justia Law

Petitioner pleaded guilty to armed burglary of a dwelling, armed kidnapping, attempted first-degree murder, and sexual battery using force or a weapon. Petitioner was sentenced to six concurrent life sentences. Petitioner’s sentences were based on offenses he committed when he was seventeen years old. After the United States Supreme Court issued its decision in Graham v. Florida, the trial court set aside Petitioner’s life sentences and, after an evidentiary hearing, resentenced Petitioner to 100 years in prison for the first count and forty years on each remaining count, to run concurrently. The Fifth District Court of Appeal affirmed Petitioner’s sentence, concluding that Graham does not apply to term-of-years sentences. The Supreme Court quashed the decision of the Fifth District, holding that Petitioner’s 100-year sentence violates Graham and the Supreme Court’s decisions in Henry v. State and Kelsey v. State. Remanded. View "Johnson v. State" on Justia Law

Prior to trial, Petitioner filed a motion in limine seeking to exclude witness testimony about the identity of the substances found at the scene of his arrest and the results from the chemical field tests performed on those substances, arguing that the witnesses were not qualified to testify as expert witnesses. The trial court denied the motion, concluding that the officer who performed the chemical field tests and identified the methaphetamine was sufficiently qualified to testify as an expert witness. Petitioner then entered an open plea of no contest to charges of conspiracy to manufacture methamphetamine, manufacture of methamphetamine, and possession of a listed chemical, reserving his right to appeal the ruling on the motion in limine, which the State agreed was dispositive of the case. Petitioner appealed, arguing that the challenged evidence failed to comply with the standard for admissibility in Daubert. The Fifth District Court of Appeal dismissed Petitioner’s appeal for lack of jurisdiction, concluding that the trial court’s order was not dispositive and therefore could not be challenged on direct appeal. The Supreme Court quashed the Fifth District’s decision, holding that, in appeals from conditional no contest pleas, stipulations of dispositiveness are binding on the appellate court. Remanded. View "Churchill v. State" on Justia Law

Petitioner pled nolo contendere to three counts of sexual battery of child under the age of twelve by a person under the age of eighteen and one count of lewd or lascivious molestation. The trial court imposed costs for each of the four convictions, resulting in costs of $603 pursuant to Fla. Stat. 938.08, $453 pursuant to Fla. Stat. 938.085, and $404 pursuant to Fla. Stat. 938.10(1). Petitioner appealed, arguing that the trial court erred in assessing the costs per count, instead of per case. The Fifth District Court of Appeal affirmed. The Supreme Court approved the decision of the Fifth District, holding that sections 938.085, 938.08, or 938.(1) require an imposition of costs per count. View "McNeil v. State" on Justia Law

The Communications Services Tax (CST) imposed a 6.8 percent tax rate on cable service and a 10.8 percent tax rate on satellite service. DIRECTV, Inc. and Echostar, LLC filed suit seeking a declaratory judgment holding the sales tax provision in the CST unconstitutional, a permanent injunction against enforcement of the provision, and a refund of taxes paid pursuant to the provision. The trial court found that the CST does not violate the Commerce Clause. The First District Court of Appeal reversed, concluding that the CST is invalid because it favors communications that use local infrastructure and therefore has a discriminatory effect on interstate commerce. The Supreme Court reversed, holding that the CST is not discriminatory in either its purpose or its effect and therefore does not violate the dormant Commerce Clause. View "Florida Department of Revenue v. DirecTV, Inc." on Justia Law

Heather Worley fell in the parking lot of Central Florida Young Men’s Christian Association, Inc. (YMCA). Worley's counsel filed a negligence suit against YMCA on behalf of Worley, seeking to recover damages, including the costs of her treatment from certain healthcare providers. During discovery, YMCA sought information as to whether Worley was referred to the relevant treating physicians by her counsel. The trial court required Worley to produce the information. Worley filed a petition for writ of certiorari with the Fifth District court of Appeal, arguing that the trial court order required the production of information protected by the attorney-client privilege. The district court denied the certiorari petition. The Supreme Court quashed the decision of the Fifth District, holding that the attorney-client privilege protects a party from being required to disclose that his or her attorney referred the party to a physician for treatment. View "Worley v. Central Florida Young Men's Christian Ass’n" on Justia Law

After a jury trial, Appellant was found guilty of premeditated first-degree murder and of attempted second-degree murder. The trial court, following the jury’s recommendation, sentenced Appellant to death. The Supreme Court affirmed Appellant’s conviction and death sentence on direct appeal. Appellant then filed a motion for postconviction relief under Fla. R. Crim. P. 3.851, raising multiple claims of ineffective assistance of counsel during the guilt phase and claiming that he was entitled to relief after the United States Supreme Court issued its decision in Hurst v. Florida. The trial court denied the motion. The Supreme Court affirmed the denial of the guilt phase claims but vacated the death sentence and remanded for a new penalty phase pursuant to Hurst v. State, holding that where the jury recommended death by a vote of ten to ten, the error in Appellant’s sentencing was not harmless beyond a reasonable doubt. View "McMillian v. State" on Justia Law

Respondent, the representative for the estate of Phil Felice Marotta, filed an action as an Engle progeny plaintiff against R.J. Reynolds Tobacco Company, an Engle defendant, asserting that Marotta’s addiction to Reynolds’ cigarettes caused his death by lung cancer. The jury found Reynolds liable on Respondent’s strict liability claim and awarded total compensatory damages of $6 million. Reynolds appealed the final judgment, and Marotta cross-appealed the trial court’s decision to preclude the jury from considering punitive damages on the product liability claim. The Fourth District Court of Appeal affirmed. The district court then certified a question to the Supreme Court. The Supreme Court answered the rephrased question in the negative, holding that federal law does not implicitly preempt state law tort claims of strict liability and negligence by Engle progeny plaintiffs. The Court approved the Fourth District’s decision related to the preemption issue but quashed the decision below to the extent that it held that Respondent was precluded from seeking punitive damages. View "R.J. Reynolds Tobacco Co. v. Marotta" on Justia Law

The State charged Defendant with attempted first-degree premeditated murder. The State did not charge or allege the elements of attempted felony murder in the charging document. During trial, the State pursued an attempted felony murder theory. Defendant objected to the State’s proffered jury instruction on attempted felony murder, but the trial court overruled the objection. During closing argument, the State argued both the attempted premeditated murder theory and attempted felony murder. The jury returned a verdict of guilty on the attempted first-degree murder counts. The Court of Appeal affirmed. The Supreme Court quashed the decision below, holding (1) because the statutory crime of attempted felony murder is a crime separate from attempted premeditated murder, the State must charge the crime of attempted felony murder in order to be entitled to a jury instruction on that crime and proceed under that theory; and (2) the State’s failure to properly charge Defendant with the crimes that it was pursuing was unconstitutional and a violation of Defendant’s right to notice of the charges against him. View "Weatherspoon v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder. The jury recommended the death penalty for each murder by a vote of seven to five. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s convictions and sentences of death. Defendant then filed a timely motion for postconviction relief, raising six claims. The circuit court denied the motion for postconviction relief after an evidentiary hearing. The Supreme Court affirmed the denial of relief as to Defendant’s ineffective assistance of guilt phase counsel claim but vacated Defendant’s sentences of death, holding that the Hurst error in Defendant’s case was not harmless beyond a reasonable doubt. Remanded for a new penalty phase proceeding. View "Robards v. State" on Justia Law