Justia Florida Supreme Court Opinion Summaries

In 1994, Petitioner filed this lawsuit against his brother and nephew (together, Respondents) alleging claims resulting from deteriorating business relationships within the family. The first trial resulted in a hung jury, and mistrial was declared. Petitioner’s subsequent amendments to his complaint culminated in a fifth amended complaint filed in 2009. The jury found in favor of Petitioner on all three counts he alleged. On appeal, the Third District Court of Appeal concluded that Respondents were entitled to judgment as a matter of law because the evidence did not support any of Petitioner’s claims. The district court also reversed on the grounds that Petitioenr’s claims were barred by the statute of limitations, as the fifth amended complaint did not relate back to the original. The Supreme Court quashed the Third District’s decision, holding (1) an amendment asserting a new cause of action can relate back to the original pleading where the claim arises out of the same conduct, transaction, or occurrence as the original; and (2) there was sufficient evidence to sustain the jury’s verdict on Petitioner’s breach of oral promise claim. Remanded. View "Kopel v. Kopel" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, involuntary sexual battery, and kidnapping. After a Spencer hearing, the trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s convictions and sentences. Defendant later filed a motion to vacate judgment and sentence pursuant to Fla. R. Crim. P. 3.851, alleging, inter alia, ineffective assistance of trial counsel. The postconviction court granted an evidentiary hearing on these two claims and then denied relief on all claims. Defendant appealed. Thereafter, the United States Supreme Court issued its decision in Hurst v. Florida, which held that the capital sentencing scheme in Florida violated the Sixth Amendment. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that counsel rendered ineffective assistance; (2) Defendant’s challenges to Florida’s execution procedures were meritless, and Defendant’s claim regarding his potential future incompetency was not ripe; and (3) any Hurst error that occurred during sentencing was harmless beyond a reasonable doubt. View "King v. State" on Justia Law

Defendant was sentenced to death for the murder of Raul Lopez and separately sentenced to death for the murder of law enforcement officer Steven Bauer. The Supreme Court affirmed in both cases. During the postconviction proceedings in both cases, Defendant alleged that he was intellectually disabled and therefore could not be executed pursuant to Atkins v. Virginia. The circuit courts denied Defendant’s intellectual disability claims. The Supreme Court affirmed. Thereafter, the United States Supreme Court held that the Supreme Court’s interpretation in Cherry of Florida’s intellectual disability statute was unconstitutional. Defendant filed successive motions for postconviction relief, arguing that the Florida Supreme court’s prior rejections of his claims were based on Cherry, an interpretation of the intellectual disability statute that the United States Supreme Court found unconstitutional in Hall v. Florida, and asserting that he was entitled to an additional evidentiary hearing on his claim. The circuit court summarily denied both motions. The Supreme Court remanded both cases to the circuit court for a single evidentiary hearing, holding that Defendant was entitled to an evidentiary hearing on his intellectual disability claim pursuant to Hall. View "Franqui v. State" on Justia Law

In 2016, Florida Power & Light Company (FPL) filed a petition requesting that the Florida Public Service Commission (PSC) approve FPL’s purchase of a power plant so that FPL could terminate its existing power purchase agreement with Cedar Bay. The Florida Industrial Power Users Group (FIPUG) and the Office of Public Counsel (OPC) intervened in the proceedings. OPC and FPL subsequently reached a negotiated settlement agreement and filed a motion for the Commission’s approval of the agreement. At a hearing on the petition FIPUG invoked the rule of sequestration of witnesses, codified in Fla. Stat. 90.616. The PSC denied the request, concluding that it had discretion as to whether to apply the rule in its proceedings. The PSC subsequently approved the settlement agreement. FIPUG appealed, arguing that the PSC erred in not sequestering the witnesses. The Supreme Court affirmed, holding that the PSC had the discretion on whether to apply the Florida Evidence Code and, in particular, the rule of sequestration during its proceedings. View "Florida Industrial Power Users Group v. Graham" on Justia Law

After undergoing surgery at Bethesda Memorial Hospital, it was discovered that a drainage tube had been left inside Plaintiff. Plaintiff and his wife filed suit against the hospital, alleging negligent removal and negligent inspection. The trial court denied Plaintiffs’ request for an instruction that would have created a presumption of negligence and shifted the burden to the hospital to disprove liability. The Fourth District Court of Appeal affirmed, concluding that when direct evidence of negligence exists, the plaintiff is not entitled to the statutory presumption arising from Fla. Stat. 766.102(3)(b). The Supreme Court quashed the decision of the Fourth District, holding that the foreign-body presumption of negligence set forth in section 766.102(3)(b) is mandatory when a foreign body is found inside the patient’s body, regardless of whether direct evidence exists of negligence or who the responsible party is for the foreign body’s presence. View "Dockswell v. Bethesda Memorial Hospital, Inc." on Justia Law

Orthopedic Specialists and various medical service providers challenged reimbursements made by Allstate Insurance Company under personal injury protection no-fault insurance policies issued to Allstate’s insureds, arguing that Allstate’s policy was ambiguous as to whether Allstate had elected to reimburse the Providers in accordance with the Medicare fee schedules provided for in Fla. Stat. 627.736(5)(a)2. The Fourth District held that the policy language was not legally sufficient to authorize Allstate to apply the Medicare fee schedules. The Supreme Court quashed the decision of the Fourth District and approved the decision of the First District in Allstate Fire & Casualty Insurance v. Stand-Up MRI of Tallahassee, P.A., holding that Allstate’s insurance policy provides legally sufficient notice of Allstate’s election to use the permissive Medicare fee schedules identified in section 627.736(5)(a)2 to limit reimbursements. View "Allstate Insurance Co. v. Orthopedic Specialists" on Justia Law

Defendant was convicted of first-degree murder, attempted first-degree murder, robbery with a firearm, and fleeing to elude a law enforcement officer. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s convictions and sentences. Defendant later filed an amended motion to vacate judgment of conviction and sentence under Fla. R. Crim. P. 3.851. After holding an evidentiary hearing, the postconviction court denied Defendant’s amended rule 3.851 motion, concluding that, due to Defendant’s failure to offer any evidence, the burden of proof had not been met. Defendant appealed the denial of postconviction relief and also filed a petition for writ of habeas corpus. The Supreme Court affirmed the denial of postconviction relief but granted the habeas petition and vacated Defendant’s death sentence, holding that a Hurst error occurred during Defendant’s penalty phase proceedings, and the error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase proceeding based on Hurst v. Florida. View "McGirth v. State" on Justia Law

Defendant was convicted of two counts of first-degree murder (premeditated and felony murder) in the death of Georgette Sturmfels, two counts of first-degree murder (premeditated and felony murder) for the death of Robert Sturmfels, and other offenses. The jury recommended two death sentences for both murders by a vote of eight to four. The trial court sentenced Defendant to death. The Supreme Court affirmed the premeditated murder convictions and death sentences, reversed the two felony murder convictions that were duplicative of the premeditated murder convictions, and remanded to the trial court. The lower court subsequently vacated one felony murder conviction for each victim. Defendant later filed his first successive motion to vacate the judgment of conviction challenging the premeditated murder convictions and death sentences, arguing an improper doubling of aggravators. The postconviction court summarily denied relief. The Supreme Court affirmed the denial of postconviction relief, holding that Defendant’s claim of improper doubling is untimely and procedurally barred. View "Gaskin v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury voted ten to two to impose the death sentence. The trial court sentenced Defendant to death. The Supreme Court affirmed. Defendant later filed a postconviction motion to vacate the judgment of conviction and sentence. The circuit court summarily denied Defendant’s postconviction motion. While Defendant’s appeal was pending, the United States Supreme Court issued its decision in Hurst v. Florida. The Supreme Court reversed the postconviction court’s order and remanded for a new penalty phase, holding that Defendant’s sentence was the result of a Hurst error, and the error was not harmless beyond a reasonable doubt. View "Kopsho v. State" on Justia Law

Defendant was convicted of one count of second-degree murder and two counts of attempted second-degree murder. Defendant appealed his second-degree murder conviction, arguing that he was entitled to relief because the jury instruction on the lesser included offense of manslaughter by act was erroneous. The district court concluded that the instruction did not constitute fundamental error. The Supreme Court reversed, holding (1) because manslaughter as a matter of degree is a next lesser offense of second-degree murder, giving an erroneous instruction on manslaughter by act constitutes fundamental error even if manslaughter is not listed immediately below second-degree murder on the verdict form; (2) in this case, the error caused by a faulty instruction on manslaughter by act was not cured by the jury’s consideration of other offenses that were also one step removed; and (3) because the jury convicted Defendant of attempted second-degree murder after being erroneously instructed on attempted voluntary manslaughter, Defendant is entitled to a new trial for the attempted homicides. Remanded with instructions that Defendant be granted a new trial. View "Daugherty v. State" on Justia Law