Justia Florida Supreme Court Opinion Summaries

Defendant was charged with a single violation of Fla. Stat. 847.0135(3)(b), which prohibits the use of a computer to solicit the consent of a parent or legal guardian of a child to engage in unlawful sexual conduct with the child, and a single violation of section 847.1035(4)(b), which prohibits traveling to meet a minor to engage in unlawful sexual conduct after using a computer to make a prohibited solicitation. The State relied upon the same conduct to charge both offenses. Defendant pleaded guilty. On appeal, the court of appeal vacated Defendant’s conviction and sentence of solicitation, concluding that Defendant’s convictions for solicitation and traveling after solicitation impermissibly placed him in double jeopardy because the Legislature had not explicitly stated its intent to allow separate convictions for these offenses based upon the same conduct and because solicitation is a lesser-included offense of traveling after solicitation. The Supreme Court approved the court of appeal’s decision, holding that Defendant’s dual convictions for solicitation and traveling after solicitation based upon the same conduct impermissibly placed him in double jeopardy. View "State v. Shelley" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, two counts of grand theft of a motor vehicle, home-invasion robbery, two counts of burglary, and escape. The trial court imposed a sentence of death for the murder. The Supreme Court affirmed the convictions and death sentence, holding, (1) the trial court did not err in denying Defendant’s motion to sever certain of the charges; (2) the trial court did not err in denying Defendant’s motion to suppress his post-arrest statement; (3) any references that were made to defendant’s incarceration at the time of his escape were not so prejudicial as to vitiate the entire trial; (4) the prosecutor did not commit misconduct during guilt-phase closing statements or penalty-phase closing arguments; (5) the sentencing order was proper; (6) Defendant’s constitutional challenge to Florida’s capital sentencing scheme was without merit under established Florida precedent; and (7) the death sentence was not disproportionate in this case. View "Fletcher v. State" on Justia Law

Defendant was convicted and sentenced to death for the murders of a correctional officer and an inmate. Defendant committed the murders while attempting to escape from prison where he was serving a life sentence for a prior murder. Defendant filed a motion for postconviction relief pursuant to Fla. R. Crim. p. 3.851. The postconviction court denied relief. Defendant appealed and simultaneously petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the postconviction court’s denial of relief and denied Defendant’s petition for a writ of habeas corpus, holding (1) Defendant did not receive ineffective assistance of trial counsel during either the guilt phase or the penalty phase; (2) the postonviction court did not err in summarily denying two of Defendant’s postconviction claims; and (3) appellate counsel did not provide ineffective assistance. View "Eaglin v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder, armed robbery, armed burglary of a conveyance, and possession of a firearm by a convicted felon. Appellant was sentenced to death. The conviction and sentence were affirmed on direct appeal. Defendant later filed a motion under Fla. R. Crim. P. 3.851 to vacate his conviction of first-degree murder and sentence of death. After an evidentiary hearing on certain of the claims raised in the motion, the circuit court denied postconviction relief. Appellant filed a notice of appeal and then filed a petition for writ of habeas corpus, contending that his appellate counsel had provided ineffective assistance. The Supreme Court affirmed the order of the circuit court denying postconviction relief and denied the petition for writ of habeas corpus, holding that none of Appellant’s claims warranted relief. View "Hayward v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, robbery, and kidnapping. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s conviction and sentence on appeal. The instant motion was Defendant’s second successive postconviction motion. In it, Defendant asserted that he must be resentenced to life based on the newly discovered evidence that his codefendant, who was convicted for first degree murder, armed robbery, and armed kidnapping and originally received a death sentence, subsequently received a life sentence. The postconviction court denied relief. The Supreme Court affirmed, holding that Defendant failed to show that his codefendant’s sentence would probably result in a life sentence for Defendant on retrial. View "Hartley v. State" on Justia Law

The Florida Judicial Qualifications Commission (JQC) determined that Laura Marie Watson, a judge of the Seventeenth Judicial Circuit, violated the Rules Regulating Professional Conduct and recommended that she be removed from office due to her actions while a practicing attorney and her demeanor during certain proceedings. The Supreme Court found that the JQC’s findings and conclusions were supported by clear and convincing evidence and that removal was the appropriate sanction, holding that Watson’s conduct in the proceedings at issue was fundamentally inconsistent with the responsibilities of judicial office. View "In re Laura Marie Watson" on Justia Law

Appellant was convicted of first-degree murder. The evidence presented at trial connecting Appellant to the murder consisted only of proof that his DNA was detected within scrapings collected from the victim’s left fingernails. Following the penalty phase and a Spencer hearing, the trial court imposed a sentence of death. The Supreme Court reversed and vacated Appellant’s conviction and sentence, holding that the record lacked competent, substantial evidence to sustain the conviction and that the State’s evidence was susceptible to the theory that, after Appellant made contact with the victim, the perpetrator killed her but left no detectable evidence at the crime scene. Remanded with directions that a judgment of acquittal be entered. View "Hodgkins v. State" on Justia Law

Certain counties filed a declaratory action against online travel companies (OTCs) arguing, inter alia, that the Tourist Development Tax (TDT) applies to the difference between the total monetary amounts the OTCs’ customers pay to them and the lesser monetary amount the OTCs remit to the hotels (a difference known as the “markup charges.”) The circuit court granted summary judgment for the OTCs, concluding (1) the TDT does not clearly impose any tax on the amount the OTCs charge their customers by way of markup charges; and (2) the OTCs, not the customers, are the entities who exercise the privilege that is taxable under the TDT. The First District Court of Appeal affirmed, holding that the privilege being exercised for purposes of the TDT is renting rooms to tourists, not the other way around. The Supreme Court approved the First District’s Decision by answering the certified question to clarify that the “local option tourist development act” imposes a tax only on the amount the property owner receives for the rental of transient accommodations and not on the total amount of consideration an online travel company receives from tourists who reserve accommodations using the online travel company’s website. View "Alachua County v. Expedia, Inc." on Justia Law

In 1993, Petitioner and Respondent, who were in a romantic relationship, entered into an oral agreement in which they agreed to purchase lottery tickets and to share equally in the proceeds of any winning lottery tickets. In 2007, Respondent purchased a winning lottery ticket and collected one million dollars. When Respondent refused to share half the proceeds with Petitioner, Petitioner filed suit for breach of an oral contract and unjust enrichment. The trial court entered judgment in favor of Respondent. The Court of Appeal affirmed in part and reversed in part, concluding (1) the breach of the alleged oral contract cause of action was barred by the statute of frauds; and (2) the district court erred in entering judgment for Respondent regarding the count for unjust enrichment. The Supreme Court quashed the Court of Appeal’s decision, holding that Petitioner’s oral agreement with Respondent to share equally in the proceeds of any winning lottery tickets they purchased fell outside the statute of frauds. View "Browning v. Poirier" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder. The trial court sentenced Appellant to death. The Supreme court affirmed Appellant’s conviction and sentence of death. Appellant later filed an amended motion to vacate judgment of conviction and sentences pursuant to Fla. R. Crim. P. 3.851. After an evidentiary hearing, the circuit court denied the postconviction motion. The Supreme Court affirmed, holding (1) Appellant was not denied the effective assistance of trial counsel; and (2) Appellant failed to establish that that he was denied access to records that related to a colorable claim. View "Twilegar v. State" on Justia Law