Justia Florida Supreme Court Opinion Summaries

In 2010, a final judgment was entered awarding Lyantie Townsend compensatory damages and punitive damages against R.J. Reynolds Tobacco Co. The judgment also awarded post-judgment interest. In 2012, an amended final judgment was entered awarding compensatory and punitive damages and ordering that the total sum would “bear interest as provided by law” from April 29, 2010. In 2014, R.J. Reynolds filed a motion to determine the rate of interest payable on the amended final judgment, contending that a 2011 amendment to Fla. Stat. 55.03(3) governed the accrual of interest on the judgment after the amended statute became effective. The trial court denied the motion. The First District Court of Appeal reversed, concluding that the 2011 amendment applied to the judgment. The Supreme Court quashed the First District’s decision, holding that the 2011 amendment to section 55.03(3) does not apply to a judgment entered between October 1998 and June 30, 2011. View "Townsend v. R.J. Reynolds Tobacco Co." on Justia Law

In 2004, when Petitioner was sixteen years old, she and her boyfriend committed murder. Petitioner was convicted of second-degree murder with a weapon, which was classified as a life felony. The trial court sentenced Petitioner to life without parole without indicating what findings of aggravating or mitigating circumstances warranted imposition of the life-without-parole sentence as opposed to a term-of-years sentence under the sentencing guidelines then in place. After the United States Supreme Court decided Miller v. Alabama, Petitioner filed a motion for postconviction relief in the form of resentencing. The circuit court denied the motion. The Second District Court of Appeal affirmed, concluding that because Petitioner was sentenced under a discretionary sentencing scheme, Miller was inapplicable to Petitioner’s life-without-parole sentence. The Supreme Court quashed the Second District’s decision, holding that Miller applies to juvenile offenders whose sentences of life imprisonment without parole were imposed pursuant to a discretionary sentencing scheme when the sentencing court, in exercising that discretion, did not take into account the individualized sentencing considerations of a juvenile offender’s youth. View "Landrum v. State" on Justia Law

In 2009, Bradley Westphal suffered a severe work-related injury. The City of St. Petersburg provided temporary total disability benefits pursuant to Fla. Stat. 440.15(2). Westphal did not reach maximum medical improvement prior to the expiration of the 104-week limitation on temporary total disability benefits and thus filed a petition for benefits pursuant to Fa. Stat. 440.15(1). The Judge of Compensation Claims (JCC) denied Westphal’s claim, thus leaving Westphal totally disabled at the cessation of temporary total disability benefits but not yet entitled to permanent total disability benefits because he could not prove he would still be totally disabled when he reached maximum medical improvement. Westphal appealed, arguing that section 440.15(2) was unconstitutional. The First District Court of Appeal “valiantly attempted to save the statute from unconstitutionality” by interpreting it so that Westphal would not be cut off from compensation after 104 weeks. The Supreme Court quashed the First District’s decision, holding that section 440.15(2)(a) is unconstitutional as applied to Westphal and all others similarly situated as a denial of access to courts under article I, section 21 of the Florida Constitution. View "Westphal v. City of St. Petersburg" on Justia Law

The First District held that Panama Commons’ right to due process was violated by applying the 2013 repeal of the ad valorem tax exemption under section 196.1978, Florida Statutes (2012), to the 2013 tax year. The court reversed and remanded, holding that applying the repeal to Panama Commons for the 2013 tax year does not violate due process. In this case, Panama Commons’ right to the tax exemption under section 196.1978 had not vested before the Legislature repealed the exemption for limited partnerships in 2013. View "Sowell v. Panama Commons L.P." on Justia Law

Plaintiff filed suit against the Bank for negligence, battery, and false imprisonment after bank employees mistakenly identified him as a bank robber. The jury awarded plaintiff a total of $2,603,000 in compensatory damages and $700,000 in punitive damages. The Third District reversed and remanded for entry of judgment for the bank. At issue is whether those who falsely report criminal conduct to law enforcement have a privilege or immunity from civil liability for the false report. The court held that a cause of action is available to one injured as a result of a false report of criminal behavior to law enforcement when the report is made by a party which has knowledge or by the exercise of reasonable diligence should have knowledge that the accusations are false or acts in a gross or flagrant manner in reckless disregard of the rights of the party exposed, or acts with indifference or wantonness or recklessness equivalent to punitive conduct. The court quashed the decision below and remanded for a new trial. View "Valladares v. Bank of America Corp." on Justia Law

Appellant, a death row prisoner, challenged the circuit court’s order denying his successive motion for postconviction relief filed under Florida Rules of Criminal Procedure 3.850 and 3.851. Appellant argued that his codefendant's statements that he saw a struggle between appellant and the victim before the victim was shot, and that he had a plea agreement in place at the time of trial, constitute newly discovered evidence warranting a new trial. Having considered appellant’s newly discovered evidence and the evidence that could be introduced at a new trial, including the evidence introduced in appellant’s prior postconviction proceedings, the court agreed with the circuit court’s conclusions that there is no probability of an acquittal on retrial. The court also concluded that appellant's argument regarding the cumulative effect of the new evidence on the outcome of the penalty phase is also without merit. The court affirmed the circuit court's denial of relief on appellant's claims under United States v. Giglio because appellant did not demonstrate that the codefendant's testimony was false and thus failed to establish the prosecutor's knowledge of any such false testimony, and Brady v. Maryland where his claim is not supported by competent, substantial evidence. Accordingly, the court affirmed the circuit court's order denying appellant's successive motion for postconviction relief. View "Melton v. Florida" on Justia Law

This case stemmed from the Department's issuance of a proposed tax assessment on American Business, for taxes and interest on the company’s internet sales transactions. The tax assessment was issued by the Department to American Business pursuant to section 212.05(1)(l) of the Florida Statutes. The court concluded that section 212.05(l) does not violate the dormant Commerce Clause as applied to American Business’s internet sales of flowers, gift baskets, and other tangible personal property where all four prongs of the Complete Auto Transit, Inc. v. Brady test have been satisfied. The court further concluded that no due process violation is present on the facts of this case where American Business’s activities have a substantial nexus to Florida. Accordingly, the court quashed the Fourth District's decision to the extent that it holds that the assessment of sales tax on sales of flowers, gift baskets, and other items of tangible personal property ordered by out-of-state customers for out-of-state delivery violates the dormant Commerce Clause. View "Florida Dept. of Revenue v. American Business USA Corp." on Justia Law

Petitioner, sixteen-years-old at the time he committed the offenses, was convicted of armed robbery and first-degree murder. Under the statute then in effect, petitioner was sentenced for the first-degree murder to a mandatory term of life imprisonment, with the possibility of parole after twenty-five years, and was sentenced to life imprisonment without the possibility of parole for the armed robbery. Under the existing statutory scheme, the Commission conducted a parole hearing and set petitioner's presumptive parole release date, which is the earliest date he may be released from prison as determined by objective parole guidelines, for the year 2130 - one hundred and forty years after the crime and far exceeding petitioner’s life expectancy. The court concluded that Florida’s existing parole system, as set forth by statute, does not provide for individualized consideration of petitioner’s juvenile status at the time of the murder, as required by Miller v. Alabama, and that his sentence, which is virtually indistinguishable from a sentence of life without parole, is therefore unconstitutional. Accordingly, the court quashed the Fourth District Court of Appeal's underlying decision upholding the sentence and remanded for resentencing. View "Atwell v. Florida" on Justia Law

The PSC approved the recovery of FPL's costs incurred through its joint venture with an oil and natural gas company to engage in the acquisition, exploration, drilling, and development of natural gas wells in Oklahoma. The court agreed with appellants that the PSC lacks the authority to allow FPL to recover the capital investment and operations costs of its partnership in the Woodford gas reserves through the rates it charges consumers. Because the PSC exceeded its statutory authority when approving recovery of FPL’s costs and investment in the Woodford Project, the court reversed the judgment. View "Citizens of the State of Florida v. Art Graham, etc." on Justia Law

The Board challenged two separate orders of the PSC. The first order is a declaratory statement that the PSC issued in response to a petition filed by the City of Vero Beach, in which the PSC declared that the City has the right and obligation under territorial orders issued by the PSC to continue to provide electric service in the territory described in the orders (which includes unincorporated portions of the County) upon the expiration of the City’s franchise agreement with the County. The court rejected the County's challenges and held that the City had standing to seek this declaration from the PSC concerning territorial orders to which the City is a party and which the County had taken the position would be voided by the Franchise Agreement’s expiration, thereby effectively evicting the City. The court also held that the PSC’s declaration is within the PSC’s authority as the entity with exclusive and superior statutory jurisdiction to determine utility service areas, and that the declaration does not impermissibly grant the County’s property rights to the City or violate the statutory prohibition against the PSC affecting a franchise fee. The second order on appeal denies the County’s petition for a declaratory statement on the ground that it failed to meet applicable statutory requirements. The court agreed and affirmed this order without further comment. View "Bd. of Cnty. Comm'r Indian River Cnty. v. Art Graham, etc." on Justia Law