Justia Florida Supreme Court Opinion Summaries

Defendant was charged with violating Fla. Stat. 384.24(2), which was enacted to prevent the spread of sexually transmissible diseases. The charge arose from a homosexual relationship between Defendant and the victim. Defendant moved to dismiss the charge under Fla. R. Crim. P. 3.190(c)(4), arguing that the term “sexual intercourse” applies only to penile-vaginal intercourse. The trial court granted the motion to dismiss based on the decision of the Second District Court of Appeal in L.A.P. v. State, which held that the term “sexual intercourse” as used in the statute applies only to “the penetration of the female sex organ by the male sex organ.” The Third District Court of Appeal reversed, holding that the term “sexual intercourse” as used in section 384.24(2) encompasses conduct beyond penile-vaginal intercourse and includes oral and anal intercourse between two men. The Supreme Court approved of the Third District’s decision and disapproved the decision of the Second District in L.A.P., holding that the term “sexual intercourse” in section 384.24(2) encompasses conduct beyond penile-vaginal intercourse. View "Debaun v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder, two counts of kidnapping, two counts of robbery, and one count of carjacking. The trial court sentenced Defendant to death for each murder and life imprisonment for each of his other convictions. The Supreme Court affirmed Defendant’s convictions and sentences. Defendant later filed an amended motion to vacate his judgment and sentences and a renewed motion for determination of intellectual disability. The postconviction court denied both motions. The Supreme Court affirmed, holding (1) the postconviction court properly determined that Defendant is not among those intellectually disabled defendants that cannot be executed; (2) with regard to every claim raised in Defendant’s amended motion to vacate his judgment and sentences, Defendant failed to demonstrate that the postconviction court erred in finding no Strickland error occurred; and (3) Defendant was not entitled to relief pursuant to Hurst v. Florida. View "Wright v. State" on Justia Law

After a jury trial, Defendant was convicted of four counts of first-degree murder, four counts of conspiracy to commit murder, two counts of manslaughter, and other crimes. The jury recommended by a vote of ten to two that Defendant be sentenced to death for one murder and also recommended a death sentence for another murder by a vote of nine to three. The trial court followed the jury’s death-sentence recommendations. The Supreme Court affirmed Defendant’s first-degree murder convictions and sentences of death on direct appeal. Defendant later filed a motion to vacate his convictions and sentences pursuant to Fla. R. Crim. P. 3.851, setting forth eight claims. The trial court denied Defendant’s Rule 3.851 motion. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the trial court’s denial of postconviction relief as to all claims except Defendant’s claim relating to the constitutionality of his penalty phase, denied habeas relief, vacated Defendant’s death sentences, and remanded for a new penalty phase, holding that Defendant’s death sentence was unconstitutional under Hurst v. Florida. View "Smith v. State" on Justia Law

Cary Michael Lambrix was convicted and sentenced to death for the 1983 first-degree murder of two victims. The Supreme Court affirmed Lambrix’s murder convictions and death sentences on direct appeal. After the Governor signed a death warrant and the execution was set, Lambrix filed both a successive motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851 and a motion for postconviction DNA testing pursuant to Fla. R. Crim. P. 3.853. The postconviction court summarily denied both of Lambrix’s motions. Lambrix appealed those orders and filed a petition for writ of habeas corpus. After the U.S. Supreme Court issued its opinion in Hurst v. Florida, the Supreme Court permitted supplemental briefing and oral argument to consider the impact of Hurst in this case. The Supreme Court ultimately affirmed the postconviction court’s denial of relief and denied Lambrix’s separate petition for habeas corpus, holding (1) Lambrix was not entitled to a new penalty phase based on Hurst v. Florida or Hurst v. State; and (2) the other grounds that Lambrix raised were devoid of merit. View "Lambrix v. State" on Justia Law

After a jury trial, Appellant was found guilty of two counts of first-degree murder and related crimes. The jury recommended death on both counts of murder. The trial court followed the jury’s recommendation and imposed two death sentences. The Supreme Court affirmed Appellant’s convictions, vacated his death sentence, and remanded for a new penalty phase based on an error in jury selection. Upon resentencing, the jury again recommended death for both murders. The trial judge sentenced Defendant to death for each count of first-degree murder. The Supreme Court affirmed the sentences of death. Appellant later filed a motion to vacate convictions for first-degree murder and sentences of death under Fla. R. Crim. P. 3.851, alleging that both guilt and penalty phase counsel were ineffective under Strickland v. Washington. The postconviction court denied each of Appellant’s claims. The Supreme Court vacated Appellant’s sentences of death, holding (1) the postconviction court did not err in denying relief on Appellant’s ineffective assistance of guilty phase counsel claim; (2) the Court declines to address Appellant’s ineffective assistance of penalty phase counsel claim; and (3) any Hurst error in Appellant’s sentencing was not harmless beyond a reasonable doubt. View "Ault v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder and first-degree felony murder, among other crimes. The jury unanimously voted to impose the death penalty. The trial court followed the jury’s recommendation and sentenced Defendant to death. Defendant appealed his convictions and sentence of death. Here the Supreme Court granted Defendant’s motion for rehearing and substituted this revised opinion for its previous opinion issued October 22, 2015. The Court affirmed Defendant’s conviction of first-degree murder and upheld his death sentence, holding (1) the evidence was sufficient to sustain Defendant’s convictions; (2) any Hurst error was harmless beyond a reasonable doubt; and (3) no other prejudicial error occurred requiring reversal of Defendant’s convictions. View "Middleton v. State" on Justia Law

In 1999, Charles Anderson was convicted and sentenced to death for first-degree murder. The Supreme Court affirmed the conviction and sentence of death on direct appeal. Anderson filed an amended motion for postconviction relief seeking to vacate his conviction and death sentence under Fla. R. Crim. P. 3.851. The trial court denied three claims after an evidentiary hearing and summarily denied the remaining claims. Anderson appealed from the denial of his motion for postconviction relief and also petitioned the Supreme Court for a writ of habeas corpus. During the pendency of Anderson’s appeal, the United States Supreme Court issued its decision in Hurst v. Florida. The Supreme Court affirmed the postconviction court’s order as to Anderson’s conviction and denied Anderson’s habeas petition but vacated the death sentence, holding that, in light of the nonunanimous jury recommendation to impose a death sentence, it cannot be said that the failure to require a unanimous verdict here was harmless. Remanded for a new penalty phase. View "Anderson v. State" on Justia Law

Dale Lee Norman was charged with open carrying of a weapon in violation of Fla. Stat. 790.053, Florida’s Open Carry Law. Section 790.053 permits individuals to carry firearms in public so long as the firearm is carried in a concealed manner. After the jury found Norman guilty of the sole count of openly carrying a firearm in violation of Florida’s Open Carry Law, the county court certified three questions to the Fourth District Court of Appeal regarding the constitutionality of the law. The Fourth District upheld Florida’s Open Carry Law under intermediate scrutiny. The Supreme Court affirmed, holding (1) the State has an important interest in regulating firearms as a matter of public safety, and Florida’s Open Carry Law is substantially related to this interest; and (2) therefore, Florida’s Open Carry Law violates neither the Second Amendment to the U.S. Constitution nor article I, section 8 of the Florida Constitution. View "Norman v. State" on Justia Law

Petitioner was convicted of multiple counts of lewd or lascivious molestation against three victims over the course of differing time periods. The trial court sentenced Petitioner to life imprisonment for the counts involving a victim under the age of twelve years old and fifteen years’ imprisonment for each of the other counts. Defendant appealed, arguing that the trial court erred in failing to include his requested jury instructions for each count pertaining to the lesser included offense of unnatural and lascivious act. The Second District Court of Appeal affirmed, concluding that Petitioner failed to preserve his claim for appeal. The Supreme Court quashed the decision below, holding (1) Petitioner sufficiently preserved his request for a lesser-included offense instruction; and (2) Petitioner was entitled to the unnatural and lascivious act jury instructions he requested. View "Wong v. State" on Justia Law

AHF-Bay Fund, LLC appealed a judgment awarding $695,158.23 in damages and prejudgment interest to the City of Largo for AHF’s failure to make payments pursuant to an agreement for payment in lieu of taxes (PILOT agreement) between the City and AHF’s predecessor in interest. On appeal, the Second District reversed, concluding that the PILOT agreement violated public policy and was therefore void. The Supreme Court quashed the decision of the Second District, holding that PILOT agreements that require payments equaling the ad valorem taxes that would otherwise be due but for a statutory tax exemption do not violate Fla. Stat. 196.1978 or Fla. Const. art. VII, 9(a). View "City of Largo v. AHF-Bay Fund, LLC" on Justia Law