Justia Florida Supreme Court Opinion Summaries

Appellant was convicted of felony murder in the death of Edward Alger and premeditated and felony murder in the death of Ann Peterson. The trial judge sentenced Appellant to death for Peterson’s murder and to life imprisonment for Alger’s murder. In 2006, Appellant filed his first successive postconviction motion, alleging that his death sentence was improper because he was intellectually disabled. The circuit court denied relief after an evidentiary hearing. In 2015, Appellant filed his second successive postconviction motion, arguing that his death sentence was unconstitutional because the United States Supreme Court’s decision in Hall v. Florida changed the definition of subaverage intellectual function to include IQ scores that are 75 or below, and because the previous intellectual disability hearing was directed at satisfying the constitutional definition of an IQ that is 70 or below, he was entitled to a new hearing. The circuit court summarily denied Appellant’s successive motion without granting a hearing. The Supreme Court reversed, holding (1) Hall applies retroactively; and (2) Appellant was entitled to a new evidentiary hearing as to his claim of intellectual disability. View "Walls v. State" on Justia Law

Defendant was charged with one count of possession of a firearm by a convicted felon. Defendant moved to dismiss the charge, arguing (1) his rifle was a permissible antique firearm or replica thereof under Fla. Stat. 790.23, the felon-in-possession statute, and (2) section 790.23 is unconstitutionally vague if convicted felons are prohibited from possessing black-powder rifles. The trial court denied the motion to dismiss, and Defendant entered a plea of no contest to one count of constructive possession of a firearm by a convicted felon. The First District Court of Appeal reversed, holding that section 790.23 is unconstitutional with respect to the possession of a replica of an antique firearm by a convicted felon. The Supreme Court approved the First District’s reversal of Defendant’s conviction but not its conclusion that section 790.23 is unconstitutionally vague, holding that Defendant was entitled to the statutory exception of the felon-in-possession statute because his firearm was a permissible “replica” of an “antique firearm” under section 790.23, as defined in Fla. Stat. 790.001(1). View "State v. Weeks" on Justia Law

Jacob John Dougan was convicted of a murder that occurred in 1974. Dougan was sentenced to death for the murder. Dougan filed an amended postconviction petition raising twenty-nine claims. The postconviction proceedings lasted more than twenty years. After an evidentiary hearing in 2013, the postconviction court granted relief as to multiple claims and vacated the murder conviction and sentence of death. Specifically, the postconviction court found (1) the State failed to disclose the full extent of its plea deal with William Hearn, the State’s only eyewitness to the murder, and allowed Hearn to testify falsely about the true nature of his deal with the State; and (2) Dougan’s guilt phase counsel was operating under two conflicts of interest and that ineffective assistance of counsel occurred in the guilt phase. The Supreme Court affirmed, holding that Dougan’s trial was tainted by the cumulative effect of the State’s violation of Giglio v. United States through the testimony of Hearn and the substandard performance of Dougan’s counsel, thus depriving Dougan of a fair and impartial trial. View "State v. Dougan" on Justia Law

After a jury trial, Clemente Javier Aguirre-Jarquin (“Aguirre”) was convicted of first-degree murder and sentenced to death. Aguirre later filed a postconviction motion under Fla. R. Crim. P. 3851, arguing that counsel was ineffective for failing to investigate alternate suspects, including Samantha Williams, who admitted to killing her family. The trial court denied relief. While Aguirre’s appeal was pending in the Supreme Court, Aguirre filed a successive postconviction motion arguing that he was entitled to a new trial based upon newly discovered evidence regarding Williams that came to light during the initial postconviction hearing and that was developed after the close of evidence in that proceeding. The circuit court denied the successive motion, concluding that Aguirre’s successive postconviction motion constituted an abuse of process and that, on the merits, Williams’ statements were inadmissible hearsay and, alternatively, that the statements made by Williams were not likely to produce an acquittal. Aguirre appealed the denial of his initial and successive postconviction motions and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court reversed the circuit court and vacated Aguirre’s convictions and sentences, holding that the cumulative effect of the newly discovered evidence required a new trial. Remanded for a new trial. View "Aguirre-Jarquin v. State" on Justia Law

This case involved a pending prosecution where the death penalty was sought. At issue was whether Florida’s newly enacted death penalty law (the Act), which was passed after the United States Supreme Court in Hurst v. Florida held that a portion of Florida’s capital sentencing scheme was unconstitutional, may be constitutionally applied to pending prosecutions for capital offenses that occurred prior to the new law’s effective date. In State v. Perry, the Fifth District Court of Appeal held that the Act could apply to pending prosecutions without offending the Constitution. The Fifth District then certified two questions of law to the Supreme Court. The Supreme Court answered, holding (1) as decided on remand in Hurst v. State, Hurst v. Florida did not declare Florida’s death penalty unconstitutional, and because Fla. Stat. 775.082(2) is limited to those cases in which the defendant was “previously sentenced to death,” the statute is inapplicable; and (2) the Act cannot constitutionally be applied to pending prosecutions because it does not require unanimity in the jury’s final recommendation as to whether the defendant should be sentenced to death, contrary to the Supreme Court’s holding in Hurst v. State. View "Perry v. State" on Justia Law

In Hurst v. State, the Supreme Court affirmed Defendant’s death sentence, which was imposed after a second penalty phase sentencing proceeding. Defendant sought certiorari review. Upon review, the United States Supreme Court reversed, holding that Florida’s capital sentencing scheme was unconstitutional to the extent that the judge, independent of a jury’s fact-finding, finds the facts necessary for imposition of the death penalty. The Court left it to the Florida Supreme Court to consider whether the error in sentencing was harmless beyond a reasonable doubt. On remand, the Supreme Court held (1) the United States Supreme Court's decision in Hurst v. Florida requires that a jury must unanimously find the critical findings necessary before the trial court may consider imposing a death sentence, and in order for the trial court to impose a sentence of death, the jury’s recommended sentence of death must be unanimous; (2) Fla. Stat. 775.082(2) does not mandate that Defendant receive an automatic life sentence; but (3) the error in Defendant’s sentencing was not harmless beyond a reasonable doubt. Remanded for a new penalty phase proceeding. View "Hurst v. State" on Justia Law

Petitioner pleaded guilty to one count of traveling to meet a minor under Fla. Stat. 847.0135(4)(b). Petitioner was sentenced to six days time served and five years of sex offender probation. One condition of Petitioner’s sex offender probation required Petitioner to successfully complete a sex offender treatment program. Petitioner was later discharged from the sex offender treatment program for refusing to admit to any sexual misconduct necessitating treatment and, as a result, was charged with violating the conditions of his probation. After a hearing, the trial court revoked Petitioner’s probation, finding that the State presented sufficient evidence of a violation. The Fifth District Court of Appeal affirmed. The Supreme Court approved the Fifth District’s decision, holding that a refusal to admit sexual misconduct can constitute a violation of probation. View "Staples v. State" on Justia Law

Johnson was covered under a homeowner’s insurance policy issued by Omega when she filed a claim to recover damages resulting from conditions which she believed to be sinkhole activity. After an initial sinkhole investigation determining that there was no sinkhole activity present on Johnson’s property, Omega denied Johnson’s claim. Johnson filed suit against Omega for breach of contract. In response, Omega hired another expert to perform an additional evaluation. The expert agreed that sinkhole activity was present on Johnson’s property. Omega accepted the evaluation report and provided payment for the damages. At issue before the trial court was whether Johnson was entitled to attorney’s fees. The trial court concluded that Omega’s agreement to pay money to Johnson amounted to a confession of judgment and awarded Johnson attorney’s fees under Fla. Stat. 627.428. The Fifth District Court of Appeal reversed, concluding that Omega did not act wrongfully or in bad faith, and therefore, section 627.428 and the confession of judgment doctrine did not apply. The Supreme Court quashed the decision below, holding that a recovery for attorney’s fees under section 627.428 requires an incorrect denial of benefits by the insurance company, not a bad faith denial. View "Johnson v. Omega Ins. Co." on Justia Law

This case involved a dispute over the validity of three stranger-originated life insurance (STOLI) policies. The United States Court of Appeals for the Eleventh Circuit certified two questions of Florida law to the Supreme Court that were determinative of the case and for which there appeared to be no controlling precedent. The certified questions involved two Florida statutes: Fla. Stat. 627.404(1), requiring that an insurable interest exist at the inception of each life insurance policy, and Fla. Stat. 627.455, providing that an insurance policy is incontestable two years after its issuance. STOLI transactions offer an insured (often an elderly one) “free” or “risk-free” insurance in exchange for transferring the policy to the investor after the two-year incontestability period has expired. The Supreme Court answered that a party cannot challenge the validity of a life insurance policy after the two-year contestability period established by section 627.455 because it is created through a STOLI scheme. View "Wells Fargo Bank, N.A. v. Pruco Life Ins. Co." on Justia Law

Two and a half months before Child’s eighteenth birthday, a private petition for an adjudication of dependency under Fla. Stat. 39.01(15)(a) and (e) was filed on Child’s behalf. The trial court denied the petition, ruling that Child did not qualify as defendant under section 39.01. The Fourth District Court of Appeal affirmed. Child appealed, arguing that the Fourth District failed to acknowledge section 39.01(15)(e) as a separate basis for a finding of child dependency. The Supreme Court dismissed the case, holding that the issue of whether Child was a dependent child under section 39.01(15)(e) was moot because Child reached majority age in 2015 and could not now be adjudicated a dependent child under Florida law. View "O.I.C.L. v. Fla. Dep’t of Children & Families" on Justia Law