Justia Florida Supreme Court Opinion Summaries

In 2006, a jury found Knight guilty of two counts of first-degree murder for the deaths of his housemate, Stephens, and her four-year-old child. Police, responding to a 911 call about noises in the apartment, found the bodies. All of the doors were locked and the apartment had not been ransacked. Knight was found outside, with cuts and bloodstains. Fingernail scrapings taken from the victim contained Knight’s DNA profile; the victim’s blood was found on Knight’s clothing. In jail, Knight described the crime to another inmate. The jury unanimously recommended a death sentence for each murder. The court sentenced Knight to death, finding that the state had proven beyond a reasonable doubt statutory aggravating circumstances: a previous conviction of another violent capital felony, that the murder was especially heinous, atrocious, or cruel, and that one victim was under 12 years of age. The court found no statutory mitigating circumstances but found eight nonstatutory mitigators. After unsuccessful appeals, Knight sought post-conviction relief, arguing he was improperly denied access to public records; the one-year deadline in Florida Rule of Criminal Procedure was unconstitutionally applied to him; he was denied adversarial testing at the guilt and penalty phases; the rule prohibiting juror interviews is unconstitutional; and Florida’s lethal injection protocol is unconstitutional. The circuit court denied all of Knight’s claims. The Supreme Court of Florida affirmed, rejecting several claims of ineffective assistance, claims of Brady violations, and challenges to the death penalty. View "Knight v. Florida" on Justia Law

Section 322.2615, Florida Statutes, authorizes a law enforcement officer to suspend driving privileges when a person is driving or in physical control of a vehicle and has a blood- or breath alcohol level of .08 or higher. An officer may also suspend the driving privilege of one who refuses to submit to a urine, breath, or blood-alcohol test. If the driver refuses to perform a lawfully requested test, the officer must notify the driver that his license will be suspended for a year, or 18 months if the driver has previously had his license suspended for failure to submit to such tests. Section 316.1932 provides that the requested tests “must be incidental to a lawful arrest” and that the officer must have “reasonable cause.” Once the license is suspended, the driver may request review by the Department of Motor Safety and Vehicles through an administrative hearing within 10 days after issuance of the notice of suspension; the review hearing essentially functions as a trial before the Department. The hearing officer’s authorization to determine the “lawfulness of the stop” is built into the provision of the essential element of whether probable cause existed; the decision may be reviewed by the circuit court. The Supreme Court of Florida held that a circuit court, conducting review under Section 322.2615, must review video evidence and reject officer testimony as competent, substantial evidence when that testimony is contrary to video evidence. View "Wiggins v. Florida Department of Highway Safety and Motor Vehicles" on Justia Law

In 1999, Mack’s family found Mack’s body, naked from the waist down, with a cord wrapped around her neck. Durousseau’s DNA was found inside Mack’s vagina. In 2003, Durousseau was indicted for first-degree murder for the deaths of five women. The similar methodology of the crimes caused investigators to conclude that Mack was one of Durousseau’s victims. Durousseau was convicted of Mack’s murder. The jury voted to impose a death sentence. The court found four aggravating factors: Durousseau was previously convicted of a felony involving the use or threat of violence; the murder was committed while the defendant was engaged in the commission of a robbery or sexual battery, was committed for pecuniary gain, and was especially heinous, atrocious, or cruel. The court did not find any statutory mitigating circumstances, but found 16 nonstatutory mitigating circumstances and sentenced Durousseau to death. The Supreme Court affirmed. Durousseau sought post-conviction relief, arguing that counsel was ineffective for failing to request additional physical and psychiatric testing and for failing to conduct meaningful voir dire. Before the hearing, Durousseau abandoned his first claim. The court denied Durousseau’s claim. While his appeal was pending, the U.S. Supreme Court decided Hurst v. Florida (2016), holding that Florida’s death penalty sentencing statute violated the Sixth Amendment. The Supreme Court of Florida affirmed the denial of post-conviction relief but vacated Durousseau’s sentences under Hurst because the jury did not make any of the requisite factual findings beyond a reasonable doubt. View "Durousseau v. Florida" on Justia Law

In 1997, Aaron sustained a catastrophic brain injury at birth due to the negligence of employees at Lee Memorial. The family retained the law firm, under a contingency fee agreement providing for payment of 40 percent of any recovery if a lawsuit was filed, plus costs, and stating that if "one of the parties to pay my claim for damages is a governmental agency, I understand that Federal and Florida Law may limit the amount of attorney fees ... in that event, I understand that the fees owed ... shall be the amount provided by law.” A jury awarded the child $28.3 million, the mother $1.34 million, and the father $1 million. Because the hospital was an independent special district of the state, the court enforced the sovereign immunity damage limitations and entered a judgment for $200,000, which was affirmed. The firm pursued a two-year lobbying effort to secure a claims bill from the Legislature. In 2012 the Legislature passed a claims bill, directing Lee Memorial to pay $10 million, with an additional $5 million to be paid in annual installments to a special needs trust for Aaron, stating that payment of fees and costs from those funds shall not exceed $100,000. No funds were awarded for the parents. The firm petitioned the guardianship court to approve a $2.5 million for attorneys’ fees and costs. The court denied the request. On appeal, the district court affirmed. The Supreme Court of Florida reversed, holding that the fee limitation in the claims bill is unconstitutional and may not stand when such a limitation impairs a preexisting contract. View "Searcy, Denney, Scarola, Barnhart & Shipley. v. Florida" on Justia Law

Florida Constitution Article X, section 25 (Amendment 7), adopted by citizen initiative in 2004, provides patients “a right to have access to any records made or received in the course of business by a health care facility or provider relating to any adverse medical incident.” “Adverse medical incident” includes “any other act, neglect, or default of a health care facility or health care provider that caused or could have caused injury to or death of a patient.” Amendment 7 gives medical malpractice plaintiffs access to any adverse medical incident record, including incidents involving other patients [occurrence reports], created by health care providers. The Federal Patient Safety and Quality Improvement Act, however, creates a voluntary, confidential, non-punitive system of data sharing of health care errors for the purpose of improving medical care and patient safety, 42 U.S.C. 299b-21(6), and establishes a protected legal environment in which providers can share data “both within and across state lines, without the threat that the information will be used against [them].” The Supreme Court of Florida reversed a holding that Amendment 7 was preempted. The Federal Act was never intended as a shield to the production of documents required by Amendment 7. The health care provider or facility cannot shield documents not privileged under state law by virtue of its unilateral decision of where to place the documents under the federal voluntary reporting system. View "Charles. v. Southern Baptist Hospital of Florida, Inc." on Justia Law

Kaczmar was convicted for first-degree murder, attempted sexual battery, and arson. Kaczmar had been previously convicted of a robbery. The state presented a victim impact statement from the victim’s brother. The defense presented testimony from Kaczmar’s family and friends, depicting Kaczmar as a good person who had a troubled upbringing. A child psychiatrist, testified that Kaczmar was traumatized by his father’s alcoholism and his own chronic drug abuse, and that although he believed Kaczmar to be competent during trial, he did not think Kaczmar knew what he was doing during the murder and did not know right from wrong. The jury recommended a death sentence. The court found that four aggravating circumstances outweighed 14 mitigation factors and imposed a death sentence . The Supreme Court of Florida affirmed Kaczmar’s convictions, but held that the court erred in finding the crimes were committed in the course of attempted sexual battery aggravators. After remand, Kaczmar waived his right to present mitigation, but agreed to reading to the jury a stipulation regarding his age (24). The jury unanimously recommended the death sentence. The state did not present additional evidence; Kaczmar admitted into evidence the transcripts of testimony from mitigating witnesses who testified during the first penalty proceeding. The Supreme Court of Florida affirmed reimposition of the death penalty, rejecting arguments that the court: erred in assigning great weight to the jury’s recommendation; improperly dismissed juror questions as “not relevant”; and erred in failing to give weight to the mitigating circumstance that Kaczmar was abused. The court also rejected claims that the death sentence was disproportionate; Florida’s death penalty statute is unconstitutional; and the prosecutor engaged in impermissible closing argument. View "Kaczmar v. Florida" on Justia Law

Housemates McCumbers, Junk, Blair, and Markus invited three women to their garage/recreation room to socialize. At 12:20 a.m. Officers Prendergast and Edu were dispatched to a noise disturbance, which had dissipated before they arrived. Prendergast testified that as he approached Markus, who was outside, he smelled marijuana. Prendergast identified himself and asked Markus to stop. Markus dropped his cigarette, raised both hands and walked backward. Prendergast instructed Markus to stop. Prendergast claimed Markus turned and ran into the garage/recreation room. The officers followed. Prendergast later testified that Markus was on the couch and resisted the officers. Additional officers arrived; they pulled Markus down. Prendergast straddled Markus to apply handcuffs, turned Markus on his side, and was alerted that there was a pistol in Markus’ waistband. McCumbers, who was in the home, testified that he handed Markus a tobacco cigarette and lit it before Markus walked outside to talk to men who were standing along the road, and that, when approached by the officers, Markus raised his hands and walked backward at a slow pace until he reached the couch. The officers had their Tasers drawn and pushed Markus, so that he “spun around.” Others testified that the officers were rough with the other occupants and that they searched the bedrooms. Markus was convicted of possession of a firearm by a convicted felon. The Supreme Court of Florida reversed. The totality of the circumstances must be considered in evaluating Fourth Amendment cases. The exigent circumstance exception of hot pursuit does not justify a warrantless home entry, search, and arrest when the underlying conduct for which there is probable cause is only a nonviolent misdemeanor and the evidence of the alleged misdemeanor is outside the home. View "Florida v. Markus" on Justia Law

A high-speed pursuit on Alabama 167 ended when both vehicles crashed into a ditch after the Camry fired shots at the patrol car. After both cars stopped, the Camry returned more gunshots; its driver, Rafsky, fled but was apprehended. Wood, a passenger, was taken into custody at the scene. Officers discovered inside the Camry a wallet belonging to Shores, the Camry’s registered owner. Shores was found dead, with his hands and legs bound, with massive head trauma. Wood told investigators that he and Rafsky had been on Shores’s property, riding dirt bikes, when Shores confronted them. Wood claimed that he discovered that Rafsky had beaten Shores and that they subsequently bound Shores. At trial, Wood also testified about his drug use on the day of the murder and that Wood had shot him in the leg. The jury found Wood guilty of first-degree murder. The court instructed the jury on aggravating factors: the capital felony was committed in a cold, calculated, and premeditated manner without any pretense of moral or legal justification; was committed while defendant was engaged, or was an accomplice in the commission of, or an attempt to commit burglary and/or robbery; and was committed to avoid arrest. The jury recommended a death sentence. After victim-impact testimony, the court considered mitigating circumstances, and sentenced Wood to death. The Supreme Court of Florida affirmed the conviction, but directed imposition of mandatory life sentence without parole. The court erred in finding two aggravating factors and in rejecting some uncontroverted mitigation. With respect to the remaining aggravating factor, that the felony was committed while Wood was engaged in commission of a burglary and robbery, the court concluded that this murder is not among the most aggravated and least mitigated, so that Wood’s death sentence was disproportionate. View "Wood v. Florida" on Justia Law

Respondents - four female students and their parents - filed a complaint against their teacher and the Palm Beach County School Board, alleging that the teacher sexually molested the children and that the School Board was negligent. Respondents later filed a third amended complaint adding a claim for violation of Title IX of the Education Amendments of 1972. The School Board filed a motion to dismiss the Title IX claim, arguing that it was barred by the statute of limitations because it id not relate back to the filing of the original complaint. The trial court agreed and dismissed the claim. The Fourth District Court of Appeal reversed, finding that the Title IX claim did, in fact, relate back to the original negligence claims. The Supreme Court approved of the Fourth District’s decision and disapproved the line of cases establishing a bright-line rule that an amendment asserting a new cause of action cannot relate back to the filing of the original complaint, holding that Respondents’ Title IX claim did not relate back to Respondents’ original pleading. View "Palm Beach County School Board v. Janie Doe 1" on Justia Law

Defendant was convicted of five counts of first-degree murder, armed robbery, armed kidnapping, and armed burglary with an assault or battery. The jury recommended a sentence of death for each count of first-degree murder by a vote of seven to five. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion by limiting the scope of voir dire; (2) the trial court erred when it failed to conduct a Frye hearing, but the error was harmless; (3) the remaining allegations of error regarding the trial court’s evidentiary rulings failed; (4) the State did not impermissibly shift the burden of proof to Defendant during its guilt phase closing statements; (5) the trial court acted within its discretion to prevent an improper argument proffered by defense counsel during the closing statement of the penalty phase; (6) substantial evidence supported Defendant’s convictions; but (7) Defendant was entitled to a new penalty phase pursuant to Hurst v. State. Remanded. View "Calloway v. State" on Justia Law