Justia Florida Supreme Court Opinion Summaries

A hospital provided medical services to twenty-nine insureds who were injured in motor vehicle accidents. After paying the hospital, the insurer requested certain documentation relating to the reasonableness of the charges pursuant to Fla. Stat. 627.736(6)(b). The hospital provided the insurer with various documents but refused to furnish copies of third-party contracts containing negotiated discount rates between the hospital and other insurers and payers, arguing that the information was not covered by subsection (6)(b). The insurer filed a petition pursuant to Fla. Stat. 627.736(6)(c) asking the trial court to compel discovery of the withheld information. The trial court ordered the hospital to produce the requested discovery. The court of appeal reversed, concluding that the trial court’s order exceeded the scope of discovery permissible under sections 627.736(6)(b) and (c). Specifically, the court ruled that discovery of facts under section 627.736(6)(c) is limited to the production of the documents described in section 627.736(6)(b). The Supreme Court approved the court of appeal’s interpretation of the scope of discovery under section 627.736(6)(c), holding that the scope of permissible discovery under subsection (6)(c) is limited to the production of documents described in subsection (6)(b). View "State Farm Mutual Automobile Insurance Co. v. Shands Jacksonville Medical Center, Inc." on Justia Law

In 2003, Respondents obtained an amended judgment against Petitioner in an Arizona federal district court. In 2006, Respondents registered the Arizona judgment in Florida under the Florida Enforcement of Foreign Judgments Act (FEFJA). In 2008, the judgment became unenforceable in Arizona because Respondents failed to renew the judgment prior to the expiration of Arizona’s five-year statute of limitations. In 2012, Respondents obtained a writ of execution in Florida. The trial court quashed the motion with prejudice, concluding that the Arizona judgment was not enforceable in either Arizona or Florida because Arizona’s five-year statute of limitations continued to control after domestication of the Arizona judgment in Florida under the FEFJA. The court of appeal reversed, holding that Florida’s twenty-year statute of limitations found in Fla. Stat. 95.11(1) applied and began to run from the date of the Arizona judgment. The Supreme Court affirmed, holding that Florida’s twenty-year statute of limitations is applicable to the enforcement of a foreign judgment after it is recorded under the FEFJA. View "Patrick v. Hess" on Justia Law

Mother and Father were divorced in Colorado. After Father died, Mother and her two minor children moved to Florida. Grandparents subsequently initiated a proceeding in Colorado seeking visitation with the children. Mother filed a separate action in Florida to register the Colorado judgment dissolving her marriage and for a judicial determination that Grandparents had no legal right to timesharing with her children. Colorado then issued a judgment awarding Grandparents visitation with the children (the Colorado order). Thereafter, the Florida court entered a final order registering and domesticating the Colorado order. Mother appealed, arguing that the Colorado order was unenforceable as a matter of Florida law and public policy because it violated “childrearing autonomy.” The court of appeal concluded that the Colorado order was entitled to full faith and credit. The Supreme Court affirmed, holding that Florida was required to enforce the Colorado order despite the fact that entry of a similar judgment by a Florida court under the circumstances presented here would be prohibited by the Florida Constitution. View "Ledoux-Nottingham v. Downs" on Justia Law

Defendant pled no contest to multiple offenses arising out of a road rage incident. The trial court adjudicated Defendant guilty and imposed a downward sentence. At the sentencing hearing, the prosecutor argued against a downward sentence. The First District affirmed the trial court’s decision to impose a downward departure sentence, concluding that the State failed to preserve the issue for appeal. The Supreme Court quashed the First District’s decision, holding that because the State timely opposed the downward departure during the same proceeding in which the sentence was imposed, the issue was properly preserved for appellate review as to the legal grounds asserted. View "State v. Wiley" on Justia Law

Defendant was convicted and sentenced to death for the first-degree premeditated murder of a corrections officer. The Supreme Court affirmed Defendant’s convictions and sentence. Defendant later filed a motion to vacate his judgment of conviction and sentence pursuant to Fla. R. Crim. P. 3.851, alleging ineffective assistance of counsel and that his execution will violate his constitutional rights. The postconviction court denied relief. Defendant appealed and also filed a petition for writ of habeas corpus, claiming that the jury instructions in capital sentencing are unconstitutional and that trial counsel was ineffective in litigating constitutional challenges to Florida’s capital sentencing statute. The Supreme Court affirmed the postconviction court’s denial of Defendant’s postconviction motion, holding (1) Defendant failed to demonstrate that the postconviction court erred in finding that no Strickland error occurred; (2) Defendant’s claim of possible incompetence at the time of execution was not ripe for review; and (3) Defendant failed to establish that he was entitled to habeas relief. View "Hall v. State" on Justia Law

Richard and Jason Debrincat filed the original civil proceeding against a group of defendants. Stephen Fischer was later added as a party defendant, but the Debrincats subsequently dropped Fischer from the underlying proceeding. Fischer then brought an action against the Debrincats for malicious prosecution. The Debrincats moved for summary judgment, arguing that the litigation privilege afforded them immunity for their conduct of joining Fischer as a defendant in the underlying lawsuit. The trial court granted summary judgment and entered a final judgment for the Debrincats. The Fourth District reversed, holding that th litigation privilege cannot be applied to bar the filing of a malicious prosecution claim. The Supreme Court approved the Fourth District’s decision, holding that the litigation privilege does not bar the filing of a claim for malicious prosecution that was based on adding a party defendant to a civil suit. View "Debrincat v. Fischer" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended death by a vote of ten-to-two. The trial court sentenced Defendant to death. The Supreme Court affirmed on direct appeal. Defendant later filed an amended motion to vacate his conviction and sentence under Fla. R. Crim. P. 3.851. The trial court denied the motion. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of postconviction relief and denied the habeas petition, holding (1) the postconviction court properly denied relief on Defendant’s Rule 3.851 motion; and (2) Defendant was not entitled to habeas relief. View "Bogle v. State" on Justia Law

After a second jury trial, Defendant was found guilty of both first-degree premeditated murder and felony murder, with burglary as the underlying felony. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s convictions but vacated his death sentence, holding (1) the trial court did not err in denying Defendant’s motion for mistrial based on juror misconduct; (2) the evidence presented by the State was sufficient to support the first-degree premeditated murder conviction and the first-degree felony murder conviction; (3) the trial court did not commit reversible error by allowing the instruction on felony murder based on burglary to go to the jury; (4) the trial court did not err in denying Defendant’s motion for change of venue; and (5) Hurst error occurred because the recommendation of death in this case was not unanimous, and the error was not harmless. Remanded for a new penalty phase proceeding. View "Dubose v. State" on Justia Law

Hojan was charged with armed robbery, armed kidnapping, attempted murder, and two murders arising out of the 2002 robbery of and shooting of employees at a Waffle House. A surviving victim gave law enforcement officers a taped statement, in which she identified Mickel and Hojan, known to her, as being involved. The jury recommended death by a vote of nine to three, and the trial court followed that recommendation, finding six aggravators, one statutory mitigator, and two nonstatutory mitigators. After an unsuccessful direct appeal, Hojan sought post-conviction relief, arguing that the survivor’s statement to an officer was not an excited utterance; the trial court improperly treated Hojan’s waiver of the opportunity to present mitigating evidence in the penalty phase as a waiver of his opportunity to present motions challenging the death penalty; his confession should have been suppressed; Florida’s death penalty statute is unconstitutional. The Supreme Court of Florida affirmed the denial of relief, finding no error under Hojan’s asserted claims, that sufficient evidence exists, and that the death sentence is proportional. The court nonetheless granted Hojan a new penalty phase, based on the U.S. Supreme Court’s 2016 decision in Hurst v. Florida. View "Hojan v. Florida" on Justia Law

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