Justia Florida Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the circuit court denying Appellant's latest successive postconviction motion seeking relief under Hall v. Florida, 572 U.S. 701 (2014), holding that Appellant did not get the benefit of Hall.Defendant was found guilty of two counts of first-degree murder and other crimes and sentenced to death. Defendant challenged his death sentence numerous times. Here, Defendant raised a second intellectual disability claim relying on Hall v. Florida, 472 U.S. 701 (2014). The circuit court summarily denied the claim. The Supreme Court reversed and remanded for an evidentiary hearing. After a hearing, the circuit court denied the motion. The Supreme Court affirmed on the basis that Hall was not retroactive, and therefore, his Hall-based intellectual disability claim failed regardless of the evidence presented at his evidentiary hearing. View "Walls v. State" on Justia Law

The Supreme Court affirmed the decision of the circuit court summarily denying Donald David Dillbeck's fourth successive postconviction motion filed under Fla. R. Crim. P. 3.851, denied Dillbeck's habeas petition, and denied two additional motions filed by Defendant, holding that Defendant was not entitled to relief in any form.Dillbeck twice committed murder and sat on death row for several decades. On January 23, 2023 Governor Ron DeSantis signed Dillbeck's death warrant. Dillbeck then filed his fourth successive postconviction motion, arguing that he was exempt from execution on three grounds. The circuit court summarily denied all three claims. Dillbeck appealed, petitioned the Supreme Court for a writ of habeas corpus, moved for a stay of execution, and requested oral argument. The Supreme Court denied all forms of relief, holding that Dillbeck failed to prove any of his allegations of error. View "Dillbeck v. State" on Justia Law

The Supreme Court approved the decision of the Second District Court of Appeal in the proceedings below, holding that an appraiser cannot be "disinterested" if he or she, or a firm in which he or she has an interest, is to be compensated for services as a public adjuster with a contingency fee.At issue was whether George Keys, the president of Keys Claims Consultants, Inc. (KCC), a homeowner's public adjusting firm, which was to be compensated on a contingency basis for its adjusting services, could subsequently serve as a "disinterested" appraiser for Jon Parrish under the language of the relevant insurance policy with State Farm. The trial court concluded that Keys could serve as Parrish's disinterested appraiser because the two had disclosed their arrangement to State Farm. The Second District reversed, concluding that Keys could not serve as Parrish's disinterested appraiser. The Supreme Court affirmed, holding that because Keys’s company, KCC, was to be compensated via contingency fee, Keys had a pecuniary interest in the outcome of the claim and could not qualify as a “disinterested” appraiser. View "Parrish v. State Farm Fla. Insurance Co." on Justia Law

The Supreme Court denied Petitioner's writ of mandamus, which the Supreme Court created as a motion for written opinion, as well as any other pending motions or requests for relief, holding that holding that Petitioner was not entitled to relief and had abused the Court's resources.As of the date of this opinion, Petitioner had filed forty-one pro se petitions or notices with the Court since August 29, 2022. The Supreme Court denied the instant petition and ordered Petitioner to show cause why she should not be barred from filing further pro se requests for relief. The Supreme Court then concluded that Petitioner failed to show cause why she should not be sanctioned and directed the Clerk of Court to reject any future pleadings or requests for relief unless such filings were signed by a member in good standing of The Florida Bar. View "A.C. v. Dep't of Children and Families" on Justia Law

The Supreme Court held that neither the common law doctrine of legislative immunity nor of governmental function immunity prohibited the statutory civil actions and penalties imposed against local governments and officials for certain violations of the firearms preemption statute, Fla. Stat. 790.33.Petitioners brought suit seeking a declaration from the circuit court that sections 790.33(3)(c),(d) and (f) were invalid because sections 790.33(3)(c) and (d) violated legislative immunity and that section 790.33(3)(f) violated governmental function immunity. The circuit court invalidated the challenged provisions. The court of appeal reversed, holding that the statutory penalty provisions at issue in this case were valid and enforceable. The Supreme Court affirmed, holding that neither legislative immunity nor governmental function immunity prohibited the statutory actions and penalties in section 790.33(3)(c), (d), or (f). View "Fried v. State" on Justia Law

In this wrongful death action, the Supreme Court approved the decision of the Fifth District Court of Appeal reversing as excessive a punitive damages award that exceeded the net compensatory damages award by a ratio of 106.7 to 1, holding that the trial court abused its discretion by denying remittitur of the excessive award.The Fifth District certified to the Supreme Court the question of whether a trial court in a wrongful death action abuses its discretion by denying remittitur of a punitive damages award "that does not bear a reasonable relation to the amount of damages proved and the injury suffered by the statutory beneficiaries." The Supreme Court answered the question in the positive and held that the trial court improperly denied remittitur of the excessive award because no reasonable trial court could have concluded that the necessary relation existed in this case. View "Coates v. R.J. Reynolds Tobacco Co." on Justia Law

The Supreme Court denied petitions in these consolidated cases alleging that the nomination of nonresident candidates for a judicial vacancy was unconstitutional, holding that the constitutional residency requirement for judges attaches at the time of appointment - not at the time of nomination.After new legislation authorized several new judgeships the Governor asked the judicial nominating commission of both the Fifth District Court of Appeal, which had four vacancies, and the Sixth District Court of Appeal, which had three vacancies, to convene and submit nominees for his consideration. Petitioners filed separate petitions seeking a writ of quo warranto directed to each judicial nominating commission alleging that the each commission's list of nominees violated the Florida Constitution and the commissions' rules of procedure because the lists included individuals who did not reside in the territorial jurisdiction of the court of appointment at the time of nomination. The Supreme Court denied the writ, holding that the residency requirement contained in Ky. Const. art. V, 8 attaches at the time of appointment. View "Boan v. Fla. Fifth District Court of Appeal Judicial Nominating Comm'n v. Fla. Sixth District Court of Appeal Judicial Nominating Comm'n" on Justia Law

The Supreme Court held that Petitioner had abused the Court's limited resources and will continue to burden the Court's resources if no action is taken and that the habeas petition filed in this case was a frivolous proceeding brought before the Court by a state prisoner, thus sanctioning Petitioner.In this case before the Court on Petitioner's petition for a writ of habeas corpus, the Supreme Court dismissed the petition as unauthorized and held that Petitioner failed to show cause why sanctions should not be imposed. Therefore, the Supreme Court directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner unless such filings were signed by a member in good standing of The Florida Bar. View "Stewart v. Dixon" on Justia Law

The Supreme Court held that Petitioner had abused the Court's limited resources and will continue to burden the Court's resources if no action is taken and that the habeas petition filed in this case was a frivolous proceeding brought before the Court by a state prisoner, thus sanctioning Petitioner.In this case before the Court on Petitioner's petition for a writ of habeas corpus, the Supreme Court dismissed the petition as unauthorized and held that Petitioner failed to show cause why sanctions should not be imposed. Therefore, the Supreme Court directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner unless such filings were signed by a member in good standing of The Florida Bar. View "Stewart v. Dixon" on Justia Law

The Supreme Court held that the first element of Florida's assault statute, Fla. Stat. 784.011(1), requires not just the general intent to volitionally take the action of threatening to do violence but also that the actor direct the threat at a target, namely, another individual.Appellant was convicted in a federal district court of possession of a firearm by a convicted felon and sentenced to enhanced penalties under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). Appellant later filed a collateral challenge to his enhanced sentence under 28 U.S.C. 2255, challenging the district court's determination that his 1998 Florida conviction for aggravated assault with a deadly weapon under Fla. Stat. 784.021(1) qualified as a "violent felony" under the ACCA. The district court denied the motion. On appeal, the Eleventh Circuit Court of Appeal certified questions of Florida law to the Supreme Court. The 17-Nov Court answered the question in the affirmative, holding that section 784.011(1) requires that the actor "direct his action at[] or target[ing] another individual." View "Somers v. United States" on Justia Law