Justia Florida Supreme Court Opinion Summaries

Defendant was convicted of multiple crimes stemming from the alleged arsons of his truck and residence. The First and Fourth District Courts of Appeal reached conflicting decisions regarding the due process implications of admitting the testimony of State experts who physically examined the vehicle prior to its destruction where the defendant’s expert did not have that opportunity. The court applied the well-established rule from Arizona v. Youngblood and held that the State’s loss or destruction of evidence potentially useful to the defense violates due process only when done in bad faith. Therefore, the court held that no due process violation occurred in defendant's case because there is no evidence of bad faith. The court approved the result of the First District’s decision in Patterson v. State and disapproved the Fourth District’s pre-Youngblood decision in Lancaster v. State. View "Patterson v. Florida" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death. On appeal, defendant challenged an order denying his motion to vacate a judgment of conviction of first-degree murder and a sentence of death under Florida Rule of Criminal Procedure 3.851. The court affirmed the circuit court's denial of defendant's motion for postconviction relief, finding that a witness for the prosecution did not recant his trial testimony and that further impeachment of the witness with his inconsistent statement would not have produced an acquittal or lesser sentence at retrial. View "Mansfield v. Florida" on Justia Law

The Judicial Qualifications Commission (JQC) accused Thirteenth Judicial Circuit Judge Gregory Holder of engaging in improper conduct while presiding over a criminal case in violation of five canons of the Code of Judicial Conduct. Judge Holder entered into a factual stipulation with the JQC admitting the charges and accepting a public reprimand and six additional hours of Continuing Judicial Education (CJE) training hours on topics related to ethics. Based on the stipulation, the JQC concluded that Judge Holder violated Canons 1, 2A, 2B, 3B(7) and 3B(9) of the Code of Judicial Conduct. The Supreme Court (1) approved the stipulation entered into by Judge Holder and the JQC, holding that there was clear and convincing evidence to support the findings of fact as to all charges; and (2) approved the stipulated discipline of a public reprimand and completion of six additional CJE training hours. View "In re Inquiry Concerning Judge Gregory Holder" on Justia Law

The Florida Judicial Qualifications Commission (JQC) alleged that Seminole County Judge Jerri Collins violated Canons 1, 2A, and 3B(4) of the Code of Judicial Conduct in the course of presiding over a domestic violence case. Judge Collins accepted full responsibility for her wrongful conduct. The JQC and Judge Collins entered into a revised consent judgment imposing as sanctions on Judge Collins a public reprimand before the Supreme Court, the successful completion of an anger management course, and attendance at the domestic violence course offered during Phase II of the Florida Judicial College. The Supreme Court approved the revised consent judgment, holding that the JQC’s findings were supported by clear and convincing evidence and that the sanctions were appropriate. View "In re Inquiry Concerning Judge Jerri Collins" on Justia Law

Petitioner was driving a truck with when the passenger opened the passenger door. The passenger suddenly left the moving vehicle and was later found dead on the ground adjacent to the roadway. Petitioner was convicted of leaving the scene of a crash that resulted in death in violation of Florida’s hit-and-run statute. The First District Court of Appeal affirmed, concluding that a driver’s vehicle may be “involved in a crash” pursuant to the statute when a passenger separates from a moving vehicle and lands on the roadway or adjacent area. The Supreme Court quashed the decision below, holding (1) the statutory phrase “any vehicle involved in a crash” means that a vehicle must collide with another vehicle, person, or object; and (2) under the facts of this case, no vehicle was involved in a collision within the meaning of the statute, and therefore, Petitioner’s conviction cannot be upheld. View "Gaulden v. State" on Justia Law

After a jury trial, Defendant was acquitted of lewd and lascivious molestation but convicted of misdemeanor battery - a lesser included offense of the molestation charge. As a special condition of his probation Defendant was ordered to undergo mentally disordered sex offender (MDSO) therapy. Defendant appealed, challenging the sex offender therapy as a condition of probation. The Third District Court of Appeal upheld the trial court’s imposition of MDSO therapy, holding (1) sex offender therapy as a condition of probation is not restricted by statute to only certain enumerated sexual offenses; and (2) the imposition of the condition comported with the standards governing probation announced by the Supreme Court in Biller v. State. The Supreme Court reversed, holding (1) the imposed probation condition was not limited to certain enumerated sex offenses; but (2) the special condition was invalid based on the Court’s decision in Biller because it did not satisfy any of the Biller factors. View "Villanueva v. State" on Justia Law

After a trial, Defendant was found guilty of murder, sexual battery, kidnapping, burglary, and grand theft. Defendant was sentenced to death for the murder. The Supreme Court affirmed the convictions and sentences. Defendant subsequently filed a motion for postconviction relief, raising seven claims of error. Defendant also filed a petition for a writ of habeas corpus. The trial court denied relief. The Supreme Court affirmed the denial of postconviction relief and denied habeas relief, holding (1) the postconviction court did not err in finding that counsel did not provide constitutionally ineffective assistance during the guilt phase or penalty phase; (2) the postconviction court did not err in denying Defendant’s Brady claim; (3) appellate counsel did not provide ineffective assistance; and (4) Defendant was not entitled to relief under Hurst v. Florida. View "Brant v. State" on Justia Law

Petitioner pled no contest to aggravated child abuse and simple child abuse. Petitioner was sentenced to a term of imprisonment and drug offender probation. The probation contained a special condition prohibiting Petitioner from associating with anyone who was illegally using drugs. Petitioner appealed, arguing that the special condition was improperly vague. The Court of Appeal upheld the special condition. Petitioner then petitioned the Supreme Court for review. The Court approved the Court of Appeal’s decision, holding (1) Petitioner’s special condition of probation, “you will not associate with anyone who is illegally using drugs,” is not unconstitutionally vague; but (2) to prove a violation of the condition the State must prove by a preponderance of the evidence the probationer’s knowledge that the person with whom he or she associated was illegally using drugs at the time of the violation. View "Demott v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder. The trial court sentenced Defendant to death for both murders. The Supreme Court affirmed Defendant’s convictions and sentences on appeal. Defendant subsequently filed an amended motion to vacate his judgment and sentences, alleging ineffective assistance of counsel during both the guilt phase and penalty phase of trial. The postconviction court granted Defendant a new penalty phase, concluding that counsel provided ineffective assistance during the penalty phase and that Defendant was deprived of a fair trial during the penalty phase by the cumulative effect of the errors. The court denied Defendant’s remaining claims. Both the State and Defendant appealed. The Supreme Court affirmed the postconviction court’s order and remanded for a new penalty phase proceeding, holding (1) competent, substantial evidence supported the postconviction court’s findings that Defendant was prejudiced by the deficient performance of his penalty phase counsel; and (2) the postconviction court did not err in finding that Defendant’s trial counsel were not unconstitutionally ineffective during the guilt phase of his trial. View "State v. Bright" on Justia Law

Defendant pleaded guilty to two counts of first-degree murder and one count of attempted first-degree murder. The trial court sentenced Defendant to death for the murders and to life imprisonment for the attempted murder. On appeal, Defendant’s principal claim was that the trial court impermissibly allowed the State to enter into evidence DVDs and photographs derived from surveillance footage without proper authentication. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion regarding the authentication of the DVDs and still photographs; (2) the trial court incorrectly applied the law regarding the avoid arrest aggravating circumstance with respect to one of the murders, but additional evidence supported the inference that Defendant acted with the intent to eliminate witnesses and avoid prosecution; (3) the sentencing order did not violate the requirements established in Campbell v. State; (4) the death sentence was proportionate in this case; (5) substantial evidence supported Defendant’s convictions; and (6) Defendant was not entitled to relief pursuant to Hurst v. Florida. Remanded for entry of a written order of competency. View "Mullens v. State" on Justia Law