Justia Florida Supreme Court Opinion Summaries

Tai Pham was convicted of first-degree murder, attempted first-degree murder, armed kidnapping, and armed burglary. The trial court entered a sentence of death. The Supreme Court affirmed the convictions and sentences. Pham later filed a motion to vacate judgment of conviction and sentence of death, raising several claims. The circuit court summarily denied some claims and held an evidentiary hearing on the remaining claims. Thereafter, the court denied relief. Pham appealed and also filed a petition for a writ of habeas corpus. The Supreme Court affirmed, holding (1) Pham failed to establish that he received ineffective assistance of counsel during either the guilt or the penalty phase; and (2) appellate counsel likewise did not provide ineffective assistance. View "Pham v. State" on Justia Law

Landowners rejected a condemning authority’s (the Authority) presuit written offer to purchase a parcel of their land. The Authority subsequently filed an action to condemn the property. After a jury determined the fair market value of the land, Landowners moved for attorney’s fees. The trial court awarded fees under Fla. Rev. Stat. 73.092(2). The Court of Appeal reversed, concluding that the attorney’s fees for the valuation proceedings were limited to those allowed by section 73.092(1). On remand, the trial court found that the Authority had caused excessive litigation and held that section 73.092(1) was unconstitutional as applied under the facts of this case because it operated to deny Landowners their right to full compensation. It then determined that the original fee award remained valid. The Court of Appeal again reversed on appeal. The Supreme Court quashed the decision of the Fifth District, holding (1) when a condemning authority engages in tactics that cause excessive litigation, section 73.092(2) shall be used separately and additionally to calculate a reasonable attorney’s fee for the hours attributable to defending against the excessive litigation; and (2) this will result in an amount that must be added to the remainder of the fee calculated utilizing the benefits achieved formula delineated in section 73.092(1). Remanded. View "Joseph B. Doerr Trust v. Cent. Fla. Expressway Auth." on Justia Law

Petitioner was convicted of arson and second-degree murder and sentenced in 2012 to life in prison on both counts. Petitioner subsequently filed more than thirty-five other extraordinary writ petitions or notices in the Supreme Court pertaining largely to four proceedings that were either frivolous, devoid of merit, or inappropriate for consideration. In this mandamus petition, Petitioner challenged the Court of Appeal’s denial of his ineffective assistance of appellate counsel petition and its imposition of pro se filing sanctions. 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. Petitioner filed a response to the order to show cause, which the Court struck as untimely. The Supreme Court then exercised its inherent authority to sanction Petitioner for abusing the judicial process and burdening the Court’s limited judicial resources, directing the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner that related to the four proceedings unless such filings were signed by a member in good standing of the Florida Bar. View "Casey v. State" on Justia Law

Petitioner was convicted of two counts of second-degree murder with a firearm and two counts of robbery with a firearm causing great bodily harm and was sentenced to a term of fifty-five years in prison. Three years later, the State moved to reduce or suspend Petitioner’s sentence pursuant to Fla. Stat. 921.186, the substantial assistance statute, explaining that it sought Petitioner’s assistance in its prosecution of a codefendant. After a hearing, the trial court denied the State’s motion. Petitioner appealed. The State countered that the order was not appealable. The Second District Court of Appeal affirmed the trial court’s decision, concluding that it had jurisdiction to review the trial court’s order denying the section 921.186 motion but that the trial court in this case misapplied the statute. The Supreme Court quashed the decision below, holding (1) orders denying relief under section 921.186 are appealable; and (2) the trial court considered improper reasons for denying the section 921.186 motion and thus abused its discretion in denying the motion. View "McFadden v. State" on Justia Law

After Plaintiff contracted peritoneal mesothelioma, he sued Union Carbide Corporation (Defendant), claiming that his disease was caused by his exposure to an asbestos product designed and manufactured by Defendant. The jury returned a verdict for Plaintiff, finding that Defendant was liable for Plaintiff’s damages, in part, under theories of negligence and strict liability defective design and failure to warn. The Third District Court of Appeal reversed. The Supreme Court quashed the Third District’s decision and remanded to the Third District with directions that the judgment be reinstated, holding (1) the Third District improperly applied the Restatement (Third) of Torts to Plaintiff’s strict liability defective design claim; and (2) the Third District improperly reversed the judgment for the failure to warn claim based on the trial court’s failure to instruct the jury on the learned intermediary defense. View "Aubin v. Union Carbide Corp." on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder, first-degree felony murder with a weapon, burglary of an occupied dwelling while armed, and dealing in stolen property. The trial court sentenced Appellant to death. The Supreme Court affirmed Appellant’s conviction of first-degree murder and upheld his death sentence, holding (1) the trial court erred in finding the avoid arrest aggravator and the cold, calculated and premeditated aggravator, but the errors were harmless; (2) Appellant’s death sentence was proportional; (3) the trial court did not abuse its discretion in denying Appellant’s motion to continue the penalty phase to set the order of penalty phase witnesses; (4) the trial court did not abuse its discretion in denying the defense funds to appoint a mitigation specialist; (5) the trial court appropriately performed the individualized sentencing required for death penalty cases; (6) the trial court did not err in denying Appellant’s motion to suppress his videotaped confession; (7) the evidence was sufficient to support the convictions; and (8) the felony murder aggravator is constitutional. View "Middleton v. State" on Justia Law

The Florida Development Finance Corporation (FDFC), a corporate and political entity, filed a complaint in the circuit court of the Second Judicial Circuit in Leon County seeking to determine the validity of a series of bonds proposed to be issued to finance qualifying improvements pursuant to the Property Assessed Clean Energy Act (PACE Act). After a hearing, the circuit court validated the PACE bonds. The Florida Bankers Association (FBA) and Robert Reynolds, a property owner in Leon County, appealed the bond validation. The Supreme court (1) dismissed the appeal brought by FBA, as FBA had no standing to appear in this appeal; and (2) affirmed the circuit court’s amended final judgment validating the FDFC special assessment revenue bonds but remanded with instructions to require FDFC to amend the bond documents as set forth in this opinion. View "Fla. Bankers Ass’n v. Fla. Dev. Fin. Corp." on Justia Law

Luke Joerg (“Luke”) was a developmentally disabled adult who had lived with his parents his entire life and had never worked. Luke was struck by a car in 2007. John Joerg (“Joerg”), Luke’s father, filed an action against State Farm Mutual Automobile Insurance Company, Joerg’s uninsured motorist carrier. Joerg filed a motion in limine to exclude evidence of any collateral source benefits to which Luke was entitled, including discounted benefits under Medicare and Medicaid. The trial court precluded State Farm from introducing evidence of Luke’s future Medicare or Medicaid benefits. The jury awarded a total of $1,491,875 in damages, including $469,076 for future medical expenses. The Second District Court of Appeal reversed the award for future damages, concluding that Luke’s Medicare benefits should not have been excluded by the collateral source rule. The Supreme Court quashed the decision below, holding that the trial court properly excluded evidence of Luke’s eligibility for future benefits from Medicare, Medicaid, and other social legislation as collateral sources. View "Joerg v. State Farm Mut. Auto. Ins. Co." on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder and robbery with a firearm or other deadly weapon. The trial court imposed a sentence of death for the murder conviction and a life sentence for the conviction for robbery with a firearm or other deadly weapon. The Supreme Court affirmed, holding (1) the prosecutor made an improper comment during closing arguments, but the comment did not rise to the level of fundamental error; (2) the heinous, atrocious, or cruel aggravating circumstance was properly applied to Defendant; (3) the admission of victim impact statements into evidence was permissible; (4) the trial court did not err in rejecting the statutory mitigator that Defendant’s ability to conform his conduct to the requirements of the law was substantially impaired; (5) Defendant’s death sentence was proportional; (6) Florida’s death penalty statutory scheme is not unconstitutional under Ring v. Arizona; and (7) there was competent, substantial evidence to support Defendant’s convictions. View "Jordan v. State" on Justia Law

Defendant pled guilty to first-degree murder and robbery with a weapon. The trial court sentenced Defendant to death. The Supreme Court affirmed the convictions and sentences on appeal. Defendant subsequently filed an amended Fla. R. Crim. P. 3.851 motion raising four claims alleging ineffective assistance of counsel. The trial court denied all claims after an evidentiary hearing. The Supreme Court affirmed the postconviction court’s denial of relief under Rule 3.851, holding that Defendant failed to demonstrate that counsel were ineffective at either the guilt or penalty phases of his trial. View "Guardado v. State" on Justia Law