Justia Florida Supreme Court Opinion Summaries

Petitioner, an inmate in state custody, filed in the Supreme Court a pro se petition for writ of mandamus. The petition was the twenty-first extraordinary writ petition or notice he had filed since 2008. The Supreme Court denied the petition and directed Petitioner to show cause why he should not be barred from filing any future pro se requests for relief and referred him to the Florida Department of Corrections for possible disciplinary action. Petitioner filed a response to the order to show cause and a motion seeking rehearing. The Supreme Court denied the motion and concluded that Petitioner failed to show cause why sanctions should not be imposed against him for his repeated misuse of the Court’s limited judicial resources and concluded that the petition filed by Petitioner was a frivolous proceeding. Accordingly, the Court directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner unless such filings are signed by a member in good standing of The Florida Bar. View "Blaxton v. State" on Justia Law

Plaintiff prevailed in an action filed against GEICO General Insurance Company. Thereafter, Plaintiff moved for attorney’s fees. Plaintiff sought discovery related to her opposition’s attorneys’ time records and propounded Lodestar/Multiplier Fee Determination Interrogatories. GEICO objected to the discovery requests, but the circuit court overruled the objections. GEICO filed a petition for writ of certiorari requesting that the Fourth District quash the orders relating to the request to produce and the interrogatory. The Fourth District granted the petition, concluding that Plaintiff failed to establish that the billing records of opposing counsel were actually relevant and necessary and that their substantial equivalent could not be obtained elsewhere. The Supreme Court quashed the decision of the Fourth District, holding that hours expended by counsel for a defendant insurance company in a contested claim for attorney’s fees filed pursuant to Fla. Stat. 624.155 and 627.428 is relevant to the issue of the reasonableness of time expended by counsel for the plaintiff, and discovery of such information, where disputed, falls within the sound decision of the trial court. View "Paton v. Geico Gen. Ins. Co." on Justia Law

At issue in this case was the definition of “manifestation” for purposes of determining class membership in the Engle class. In Engle v. Liggett, the Supreme Court held that membership in the Engle class is established when the tobacco-related disease or medical condition “first manifested itself.” In the instant case, Plaintiff, as the personal representative of the estate of her deceased husband (Decedent), filed suit against R.J. Reynolds Tobacco Company. The trial court instructed the jury that “manifestation” occurred when Decedent experienced symptoms of or was diagnosed with peripheral vascular disease. Decedent was not diagnosed until after the November 21, 1996, cut-off date for Engle class membership. The jury decided the issue of Engle class membership in favor of Plaintiff and later found in favor of Plaintiff on the majority of her claims. The Court of Appeal largely affirmed, concluding that Decedent’s “pre-1996 knowledge of a causal link between symptoms and tobacco” was unnecessary for class membership. The Supreme Court approved the Court of Appeal’s definition of “manifestation,” holding that “manifestation” for purposes of establishing membership in the Engle class is defined as the point at which the plaintiff began suffering from or experiencing symptoms of a tobacco-related disease or medical condition. View "R.J. Reynolds Tobacco Co. v. Ciccone" on Justia Law

Noel Plank, a prospective juror, was found in direct criminal contempt for coming to the courthouse drunk and thereby disrupting the jury selection and distracting the other jurors. The trial judge sentenced Plank to thirty days in jail. Plank appealed, arguing that the trial court erred by not appointing him counsel or giving him an opportunity to seek counsel for the contempt proceeding. The Court of Appeal affirmed. At issue on appeal was whether an individual is entitled to counsel in direct criminal contempt proceedings before incarceration is imposed as punishment. The Supreme Court quashed the Court of Appeal’s decision and directed that Plank’s conviction for direct criminal contempt be vacated, holding (1) there is no requirement to appoint counsel in direct criminal contempt proceedings where a defendant is incarcerated for less than six months; but (2) because the allegedly contemptuous conduct for which Plank was incarcerated did not involve conduct that occurred only in the presence of the court, the trial court erred in classifying the conduct as direct criminal contempt. View "Plank v. State" on Justia Law

Defendant pleaded guilty to first-degree murder. The trial court sentenced Defendant to death after concluding that the aggravating circumstances outweighed the mitigating circumstances. The Supreme Court affirmed, holding (1) the trial court did not err in accepting Defendant’s waiver of the presentation of mitigating circumstances without appointing special counsel to investigate and present such evidence on his behalf; (2) the presentence investigation report considered by the trial court was sufficiently comprehensive to satisfy the applicable requirements; (3) the trial court did not violate Defendant’s procedural rights by preparing the sentencing order before the sentencing hearing; (4) the trial judge properly discussed in the sentencing order the evidence of Defendant’s motive in committing the murder; (5) Defendant’s guilty plea was knowing and voluntary; and (6) the sentence of death was proportional. View "Robertson v. State" on Justia Law

Petitioner filed suit against Mauna Loa Investments, LLC alleging that she was injured when she fell on property owned, maintained, and/or controlled by Mauna at the time of the injury. The trial court entered a default judgment against Mauna. Petitioner subsequently filed a complaint in a separate action against Iberia NV, LLC, alleging that she was injured on the same property and alleging that Iberia owned, maintained, and/or controlled the property at the time of the injury. The Iberia case was consolidated with Petitioner’s suit against Mauna. Mauna filed an amended motion to set aside the default, alleging that the Iberia complaint constituted Plaintiff’s admission that her prior allegations in the Mauna complaint were false. Thereafter, Petitioner voluntarily dismissed without prejudice the Iberia complaint. The circuit court ultimately denied Mauna’s motion. After a jury trial solely on damages, the jury found for Petitioner. The Court of Appeal reversed the judgment and vacated the default, concluding that Petitioner’s Mauna complaint failed to state a cause of action. The district court reached its conclusion based on its consideration of the complaint in the Iberia case. The Supreme Court reversed, holding that the district court erred in considering documents outside the complaint in determining the complaint’s sufficiency to state a cause of action. View "Santiago v. Mauna Loa Invs., LLC" on Justia Law

Maurice Soffer died from lung cancer caused by smoking. Soffer’s widow, Lucille Soffer, brought a wrongful death action against R.J. Reynolds Tobacco Company pursuant to Engle v. Liggett Group, Inc., alleging four causes of action, all of which had been pled in the Engle class litigation. Prior to trial, Soffer moved to amend her complaint to add a demand for punitive damages. The trial court granted the motion to amend. A judgment was entered for Soffer in the amount of $2 million. Soffer appealed, arguing that the trial court erred in instructing the jury that it was prohibited from awarding punitive damages on the counts for negligence and strict liability based on the procedural posture of the original Engle class action. The Court of Appeal affirmed, holding that individual members of the Engle class action are bound by the procedural prosture of the Engle class representatives when they pursue their individual lawsuits and, thus, cannot seek punitive damages on negligence or strict liability counts. The Supreme Court quashed the Court of Appeal’s decision, holding that the individual members of the Engle class action are not prevented from seeking punitive damages on all claims properly raised in their subsequent individual actions. View "Soffer v. R.J. Reynolds Tobacco Co." on Justia Law

Petitioner was convicted of aggravated assault and cocaine possession, among other criminal offenses, and was sentenced to fifteen years in prison. The court of appeal affirmed Petitioner’s convictions and sentences. Petitioner began filing with the Supreme Court in 2011 and, since that time, filed twenty-three extraordinary writ petitions or notices, none of which were successful. The petition in this case was a pro se petition for writ of mandamus filed with the Supreme Court. The Supreme Court denied the petition and retained jurisdiction to pursue possible sanctions against Petitioner based upon his numerous meritless and inappropriate filings. The Supreme Court imposed sanctions, concluding that Petitioner failed to show cause why sanctions should not be imposed against him for his repeated misuse of the Court’s limited judicial resources and directed the Clerk of Court to reject any future pleadings or requests for relief submitted by Petitioner regarding his criminal case unless such filings are signed by a member in good standing of the Florida Bar. View "Green v. State" on Justia Law

After a jury trial, Defendant was convicted of one count of second-degree murder and one count of shooting at, into, or within an occupied vehicle. During trial, Defendant asserted that he shot at the vehicle in which the victim was a passenger both in self-defense and defense of others. On appeal, Defendant argued for the first time that the jury instruction conflicted with regard to the duty to retreat. The court of appeal reversed Defendant’s convictions and remanded for a new trial, holding that the instructions at issue were contradictory and negated Defendant’s defense of self-defense and defense of others. The Supreme Court quashed the decision below, holding that the instructions at issue clearly stated the law and were not confusing, misleading, or contradictory with regard to the duty to retreat where there is a question of fact as to who was the initial aggressor. Remanded. View "State v. Floyd" on Justia Law

Defendant was charged with possession with intent to sell or deliver and possession of more than twenty grams of cannabis. Defendant appealed, arguing that the trial court erred in refusing to grant his motion for judgment of acquittal. Recognizing that Defendant was convicted under a theory of constructive possession, the court of appeal affirmed Defendant’s conviction, finding that the circumstantial evidence standard should apply only where both elements of constructive possession are proven solely by circumstantial evidence. The Supreme Court approved the court of appeal’s decision and upheld Defendant’s conviction for constructive possession, holding (1) the circumstantial evidence standard of review continues to apply in Florida; (2) with direct evidence of dominion and control, Defendant’s case could not be considered wholly circumstantial, and therefore, the circumstantial evidence standard of review does not apply; and (3) the State produced sufficient evidence that a rational jury could find the elements of the crime beyond a reasonable doubt. View "Knight v. State" on Justia Law