Justia Florida Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of first-degree premeditated murder. The jury unanimously recommended a sentence of death. The trial court followed the jury’s recommendation and sentenced Defendant to death. The Supreme Court affirmed, holding (1) the trial court did not err in admitting evidence of collateral crimes; (2) the trial court did not fundamental error by failing sua sponte to instruct the jury regarding the limited purpose of collateral crime evidence prior to its admission; (3) the trial court did not err in failing to appoint special counsel to present mitigation evidence during the penalty phase; (4) Defendant was not entitled to resentnecing on the grounds that a prior violent felony aggravating circumstance was premised on invalidated convictions because Defendant again stood trial and was convicted; (5) Defendant’s death sentence was constitutional, and any Hurst error was harmless beyond a reasonable doubt; (6) the evidence was sufficient to support the jury’s verdict; and (7) Defendant’s death sentence was proportional. View "Jones v. State" on Justia Law

After an evidentiary hearing, the Florida Judicial Qualifications Commission (JQC) determined that Circuit Judge Andrew J. Decker, III violated certain provisions of the Code of Judicial Conduct during his judicial campaign and certain Florida Bar Rules of Professional Conduct before his judicial campaign. The JQC hearing panel recommended a ninety-day suspension, public reprimand, and payment of costs of the proceedings. The Supreme Court concluded that, with limited exceptions, the hearing panel’s findings were supported by clear and convincing evidence and modified in part the recommended sanction and imposed a six-month suspension, public reprimand, and payment of costs of the proceedings on Judge Decker. View "Inquiry Concerning Judge Andrew J. Decker, III" on Justia Law

At issue in this case was a collective bargaining agreement (CBA) between the union that represented officers employed by the City of Miami’s police department (the Union) and the City of Miami (the City). After the City declared a “financial urgency” in 2010, the City notified the Union that it intended to implement changes to the CBA. When the parties were unable to come to an agreement, the City’s legislative body voted to unilaterally alter the terms of the CBA and adopted changes regarding wages, pension benefits, and other economic terms of employment. The Union filed an unfair labor practice (ULP) charge with the Public Employees Relations Commission (PERC), arguing that the City acted improperly by unilaterally changing the CBA before completing the impasse resolution process provided for in Fla. Stat. 447.4095. PERC dismissed the Union’s ULP charge. The First District Court of Appeal affirmed. The Supreme Court quashed the First District’s decision, holding (1) an employer must demonstrate that funds are available from no other possible reasonable source before unilaterally modifying a CBA; and (2) modification can only be made after completing the impasse resolution process set forth in section 447.4095. View "Headley v. City of Miami" on Justia Law

Defendant was convicted of sexual battery on an inmate by a law enforcement officer and was sentenced to ten years of imprisonment and thirty years of community service. The court of appeal affirmed. Since 2012, Defendant has filed twelve previous extraordinary writ petitions pertaining to his conviction and sentence. All petitions have been frivolous, devoid of merit, or inappropriate for consideration by the Supreme Court. In the instant case, Defendant filed a habeas petition challenging his conviction and seeking immediate release and/or damages on several grounds. The Supreme Court found that the petition was a frivolous proceeding brought before the Supreme Court by a state prisoner and directed the clerk of court to reject any future pleadings or requests for relief submitted by Defendant pertaining to his criminal case unless such filings were signed by a member of the Florida Bar. View "Hawkins v. Jones" on Justia Law

MMB Properties filed a complaint alleging that Planned Parenthood of Greater Orlando’s use of property located at a medical complex violated the Declaration of Restrictions. The complaint sought a permanent injunction preventing Planned Parenthood from performing certain activities. MMB Properties then filed a motion for a temporary injunction. The trial court granted the motion. Planned Parenthood filed a motion to modify or dissolve the temporary injunction, without success. Planned Parenthood appealed the temporary injunction and the denial of its motion to modify or dissolve the temporary injunction. The Fifth District Court of Appeal held that Planned Parenthood needed to establish changed circumstances in order to modify or dissolve the temporary injunction, which it did not do. The Fifth District also affirmed the portion of the temporary injunction enjoining Planned Parenthood from performing abortions. The Supreme Court quashed the Fifth District’s decision to the extent it affirmed the trial court’s temporary injunction, holding (1) a trial court abuses its discretion in not modifying or dissolving a temporary injunction when a party shows clear misapprehension of the facts or clear legal error, regardless of whether the movant shows changed circumstances; and (2) the order enjoining Planned Parenthood from performing abortions was not based on competent, substantial evidence. View "Planned Parenthood of Greater Orlando, Inc. v. MMB Properties" on Justia Law

After a jury trial, Defendant was found guilty of one count of robbery with a firearm. The jury also found that Defendant did “actually possess” a firearm during the robbery. The trial court sentenced Defendant to twenty-five years in prison and, based on the finding of actual possession, imposed a ten-year mandatory minimum sentence. The Fourth District Court of Appeal affirmed the conviction and sentence. Defendant later filed a motion to correct illegal sentence, arguing that his sentence was illegal because the allegation in the information that he carried a firearm was not sufficient to place him on notice that he was subject to an enhanced sentence. The circuit court denied the motion. The Fourth District affirmed, concluding that Defendant waived any challenge to the sufficiency of the information or the imposition of a mandatory minimum sentence. The Supreme Court approved the Fourth District’s decision, holding that the alleged defect in the charging document did not result in an illegal sentence subject to correction under Fla. R. Crim. P. 3.800(a). View "Martinez v. State" on Justia Law

Defendant was charged with the murder of her husband. Defendant filed a motion to suppress statements she made to police on two occasions at the police station after being interrogated by the police. The trial court granted the motion to suppress, finding that Defendant was in custody for the purpose of administering Miranda warnings based on the totality of the circumstances, and because she was not advised of her Miranda rights, the statements must be suppressed. The Fifth District Court of Appeal reversed, concluding that “a reasonable person in Defendant’s position would have felt free to terminate the interviews.” The Supreme Court quashed the Fifth District’s decision, holding that Defendant was in custody for purposes of Miranda warnings during both interrogations, and therefore, Defendant’s constitutional right against self incrimination was violated by the police’s failure to administer Miranda warnings before proceeding with the custodial interrogations. Remanded. View "Myers v. State" on Justia Law

Petitioner was involved in a single-vehicle car crash in which a single fatality occurred. After a jury trial, Petitioner was found guilty of DUI serious bodily injury and sentenced to five years of incarceration. Petitioner appealed, arguing that the trial court erred by admitting the results of a blood test because the law enforcement officer did not have probable cause to believe Petitioner was under the influence of alcoholic beverages before requiring him to submit to the blood draw taken after the traffic accident, as required by Fla. Stat. 316.1933(1)(a). The Third District Court of Appeal affirmed, ruling that the blood draw was constitutionally permissible under the fellow officer rule and, alternatively, that voluntary consent supported the blood draw. The Supreme Court quashed the decision of the Third District, holding (1) the fellow officer rule was inapplicable because there was no communication between the officers concerning Petitioner; and (2) Petitioner’s consent was involuntary because it was given in response to a threat to suspend his driver license for refusing to give consent by an officer lacking probable cause. View "Montes-Valeton v. State" on Justia Law

After a jury trial, Appellant was found guilty of the kidnapping and murder of Vincent Binder. The jury recommended that Appellant be sentenced to death by a unanimous vote. The trial court agreed with the jury’s unanimous vote and imposed a death sentence. The Supreme Court affirmed, holding (1) the trial court did not err in overruling the State’s use of a peremptory challenge to an African-American juror; (2) excluding people from the jury venire due to their age does not violate the Constitution; (3) the trial court did not err in permitting the State to introduce evidence of other crimes or acts for the purpose of proving a material fact in issue; (4) the cumulative effect of any improper closing comments made by the prosecutor did not entitle Appellant to a new trial; (5) the trial court’s rulings during the penalty phase did not deprive Appellant of a fair trial; (6) Appellant was not entitled to relief under Hurst v. Florida and Hurst v. State; and (7) the death penalty was not disproportionate. View "Truehill v. State" on Justia Law

Here the Supreme Court considered two petitions for writs of prohibition filed in Evans v. State and Rosario v. State. In Evans, the trial court determined that it would death qualify the jury in Evans’ first-degree murder trial and instruct the jury that Evans could receive a death sentence if the jury unanimously made the requisite findings of fact and unanimously recommended a death sentence. In Rosario, the trial court determined that the State was prohibited from seeking the death penalty in a pending prosecution and ordered that the case proceed with a mandatory life maximum penalty. The Fifth District Court of Appeal granted the State’s petition for a writ of prohibition. The Supreme Court denied Evans’ and Rosario’s petitions for writs of prohibition, holding that the trial courts in both cases may proceed with death qualifying juries, as, pursuant to the Court’s holdings in Hurst v. State and Perry v. State, the revised statutory scheme in chapter 2016-13, Laws of Florida, can be applied to pending prosecutions for a jury recommendation of death if twelve jurors unanimously determine that a defendant should be sentenced to death. View "Evans v. State" on Justia Law