Justia Florida Supreme Court Opinion Summaries

Appellant was convicted of four counts of first-degree murder and sentenced to death for each murder. After Governor Scott signed the death warrant Appellant filed a third successive motion for postconviction relief, claiming, inter alia, that Florida’s death penalty statute is unconstitutional. Appellant also filed extensive public records requests with several entities. Appellant was provided with some, but not all, of the requested records. The circuit court summarily denied Appellant’s third successive postconviction motion. Appellant subsequently filed a fourth successive postconviction petition, asserting, inter alia, that Florida’s lethal injection protocol is unconstitutional because of the use of midazolam. The circuit court denied Appellant’s fourth successive motion for postconviction relief. The Supreme Court affirmed the denial of Appellant’s third and fourth successive motions for postconviction relief, as well as the circuit court orders sustaining the objections to the public records requests, holding (1) Appellant’s challenge to the use of midazolam failed; (2) Appellant’s public records challenges were without merit; and (3) Appellant was not entitled to relief on the remainder of his claims. View "Correll v. State" on Justia Law

This case was before the Supreme Court on appeal from a circuit court judgment validating a proposed bond issue. The Court affirmed the circuit court’s decision to validate the bonds but remanded with instructions for the circuit court to require Leon County Energy Improvement District to amend the financing agreement to remove all references to judicial foreclosure. The financing agreement was virtually identical to the financing agreement in Thomas v. Clean Energy Coastal Corridor, also decided today. The Court wrote further in order to recede from its decision in Meyers v. City of St. Cloud, in which the Court concluded that citizens and taxpayers who failed to appear in the bond validation proceedings in circuit court nonetheless had the right to appeal from the trial court’s decision. The Court held that the conclusion reached by Meyers cannot be sustained and that citizens and taxpayers are not entitled to appeal without having formally participated in the trial proceedings. View "Reynolds v. Leon County Energy Improvement Dist." on Justia Law

Clean Energy Coastal Corridor, whose purpose is to finance through the issuance of bonds certain qualifying improvements to real property as authorized by the Property Assessed Clean Energy (PACE) Act, adopted a bond resolution authorizing the issuance of revenue bonds in an amount not to exceed $500,000,000 for the purpose of financing qualifying improvements. Clean Energy filed a complaint to validate those bonds. The only argument relevant to this appeal regarding Clean Energy’s authority to issue the bonds was that the bonds could not be validated because the financing agreement to be signed by Clean Energy and property owners participating in the PACE Program purported to authorize a remedy for the collection of unpaid assessments that was not authorized by Florida law. After a show-cause hearing, the circuit court validated the proposed bond issue. The Supreme Court affirmed the circuit court’s final judgment validating the bonds but remanded for the circuit court to require Clean Energy to amend the financing agreement, as the financing agreement’s references to judicial foreclosure were inconsistent with its requirement that the collection of non-ad valorem assessments must be accomplished pursuant to Fla. Stat. 197’s uniform method. View "Thomas v. Clean Energy Coastal Corridor" on Justia Law

After Harry Jones died, a notice to creditors was published. Neither Harry’s ex-wife, Katherine Jones, nor her guardian was ever served with a copy of the notice. Less than two years after Harry’s death, the guardian of Katherine, Edwards Golden, filed a statement of claim in the probate court asserting that Harry’s estate owed Katherine money based on a marital settlement agreement. Katherine subsequently died, and Golden was appointed as the curator of her estate. The probate court struck Golden’s claim as untimely. The Fourth District Court of Appeal reversed and remanded to the probate court to determine whether Katherine or her guardianship was a known or reasonably ascertainable creditor. Specifically, the court ruled that if a known or reasonably ascertainable creditor is never served with a copy of the notice to creditors, the creditor’s claim is timely if filed within two years of the decedent’s death. The Supreme Court approved of the Fourth District’s decision, holding that the three-month limitations period prescribed in Fla. Stat. 733.702(1) is not applicable to known or reasonably ascertainable creditors who are never served with a copy of the notice to creditors, and the claims of such creditors are timely if filed within two years of the decedent’s death under Fla. Stat. 733.710. View "Jones v. Golden" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder on theories of both premeditation and felony murder and related crimes. The trial court sentenced Defendant to death, finding that the aggravating factors outweighed the mitigating factors. The Supreme Court affirmed, holding (1) the trial court did not err in assigning weight to the felony probation aggravator; (2) the trial court did not err in applying the heinous, atrocious, or cruel aggravator to Defendant; (3) the trial court did not err in instructing the jury on attempted voluntary manslaughter; (4) the evidence was sufficient to support Defendant’s convictions for robbery, attempted robbery, and arson; (5) the trial court did not abuse its discretion in responding to a jury question during deliberations; (6) even if the court erred in admitting hearsay statements into evidence, there was no reasonable possibility that the admission of these statements contributed to the conviction; and (7) Defendant’s death sentence was a proportionate sentence. View "Cannon v. State" on Justia Law

The Condominium Association of La Mer Estates filed a complaint to quiet title to the condominium unit. The Association served Bank of New York Mellon, which was assigned the mortgage securing the property. The Association obtained a default final judgment and quieted title against the Bank. The Bank later moved to vacate the quiet title judgment on grounds that it was void because the complaint failed to state a cause of action. The trial court granted the motion. The Fourth District Court of Appeal reversed, ruling that, although the complaint failed to state a cause of action, the resulting default judgment was voidable, rather than void. The Supreme Court approved the decision of the Fourth District, holding that a default judgment is voidable, rather than void, when the complaint upon which the judgment is based fails to state a cause of action. View "Bank of New York Mellon v. Condo. Ass’n of La Mer Estates, Inc." on Justia Law

In 2004, Defendant was convicted of first-degree murder. The trial court entered an order sentencing Defendant to death. The Supreme Court affirmed on appeal. Defendant filed a motion for postconviction relief under Fla. R. Crim. P. 3.851 alleging ineffective assistance of counsel and a Brady/Giglio claim. The court denied Defendant’s motion to vacate his conviction and sentence in its entirety. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus, alleging ineffective assistance of counsel. The Supreme Court (1) affirmed the order denying postconviction relief, holding that the postconviction court did not err in its rulings; and (2) denied Defendant’s petition for a writ of habeas corpus, holding that Defendant failed to establish that he received ineffective assistance of counsel. View "Hernandez v. State" on Justia Law

In 2005, Defendant was convicted of first-degree murder, attempted armed robbery, and grand theft of a motor vehicle. The trial court sentenced Defendant to death for the murder conviction. The Supreme Court affirmed on appeal. In 2009, Defendant filed a second amended motion for postconviction relief, alleging several claims. The postconviction court denied Defendant’s motion to the extent it requested a new guilt phase but granted the motion to the extent that it requested a new penalty phase. Defendant appealed and, in addition, filed a petition for a writ of habeas corpus, asserting four claims. The Supreme Court affirmed the postconviction court’s order that denied Defendant’s request for a new guilt phase trial and denied his petition for a writ of habeas corpus, holding (1) the postconviction court did not err in its rulings; and (2) Defendant was not entitled to relief on his habeas corpus claims. View "Blake v. State" on Justia Law

Before they married, Dianne and Harry Hahamovitch entered into a prenuptial agreement. The two remained married for twenty-two years. In 2008, the parties filed for dissolution of marriage. The trial court concluded that the prenuptial agreement was valid. The court of appeal upheld the conclusion and concluded that the language of the agreement was broad enough to waive Dianne’s right to any asset titled in Harry’s name that was acquired during the marriage or that appreciated in value due to marital income or efforts during the marriage. The Supreme Court affirmed the court of appeal’s decision, holding that, where a prenuptial agreement provides that neither spouse will ever claim any interest in the other’s property, states that each spouse shall be the sole owner of property purchased or acquired in his or her name, and contains language purporting to waive and release all rights and claims that a spouse may be entitled to as a result of the marriage, those provisions serve to waive a spouse’s right to any share of assets titled in the other spouse’s name, even if those assets were acquired during the marriage or appreciated in value during the marriage due to the parties’ marital efforts. View "Hahamovitch v. Hahamovitch" on Justia Law

On February 19, 2015, the Florida Judicial Qualifications Commission (JQC) filed in the Supreme Court a notice of formal charges charging Eleventh Judicial Circuit Judge Jacqueline Schwartz with violations of the Code of Judicial Conduct. Judge Schwartz admitted her misconduct and stipulated to the sanctions of a public reprimand and a letter of apology. On April 29, 2015, the Supreme Court rejected the parties’ stipulation, concluding that the terms of the stipulation were inadequate to address the violations committed by Judge Schwartz. Judge Schwartz and the JQC subsequently filed a revised consent judgment in which the parties agreed to the terms outlined in the April 29, 2015 order. The Supreme Court approved the revised consent judgment, which imposed the following sanctions upon Judge Schwartz: a public reprimand before the Supreme Court, a thirty-day suspension without pay, a requirement that Judge Schwartz write a letter of apology, and a $10,000 fine. View "Inquiry Concerning Judge Jacqueline Schwartz" on Justia Law