Justia Florida Supreme Court Opinion Summaries

At issue in this case was the evidentiary standard of proof that applies in an initial license application proceeding under Florida’s Administrative Procedure Act. In 2011, a family day care licensed under Fla. Stat. 402.313 submitted an initial application for a large family child care home license under Fla. Stat. 402.3131. An administrative law judge (ALJ) recommended that the Department of Children and Families (DCF) grant a provisional large family child care license. DCF rejected the ALJ’s recommendation and denied the day care’s application for a large family child care home license. In so doing, DCF rejected the ALJ’s conclusion of law that the clear and convincing evidence standard applied to the denial of the day care’s initial license application, instead concluding that it needed only to produce competent substantial evidence of its stated reasons for denying the application. The Second District Court of Appeal reversed and remanded for DCF to enter a final order adopting the ALJ’s recommendation, concluding that the clear and convincing evidence standard applied. The Court quashed the Second District’s decision, holding that the preponderance of the evidence standard applied in this initial license application proceeding. View "Fla. Dep’t of Children & Families v. Davis Family Daycare Home" on Justia Law

Defendant was fifteen years old when she took part in an attempted robbery that resulted in a death. Defendant was convicted of first-degree murder, among other crimes. The trial court imposed a mandatory sentence of life imprisonment without the possibility of parole for the murder. A decade after Defendant’s convictions and sentences became final, the U.S. Supreme Court issued its decision in Miller v. Alabama. Defendant subsequently filed a motion for postconviction relief and to correct an illegal sentence, asserting that her sentence was unconstitutional under Miller and, therefore, she was entitled to be resentenced. The trial court denied the motion on the basis of the First District Court of Appeal’s precedent in Gonzales v. State, which held that Miller did not apply retroactively. The First District affirmed. The Supreme Court reversed, holding (1) the Supreme Court’s decision in Miller applies retroactively to juvenile offenders whose convictions and sentences were final at the time Miller was decided; and (2) based on the Court’s decision in Horsley v. State, the appropriate remedy for any juvenile offender whose sentence is now unconstitutional under Miller is to conduct a resentencing proceeding consistent with the provisions of chapter 2014-220, Laws of Florida. View "Falcon v. State" on Justia Law

Defendant was seventeen years old when he participated in the robbery of a convenience store, during which an owner was killed. The jury convicted Defendant of first-degree murder, among other charges. Defendant was sentenced to life imprisonment without the possibility of parole for the murder. While Defendant’s appeal was pending, the U.S. Supreme Court decided Miller v. Alabama. Defendant subsequently filed a motion to correct his sentence, asserting that he was entitled to be resentenced with individualized consideration based on Miller. The trial court agreed with Defendant but concluded that it did not have the discretion to consider a term of years as a sentencing option. Thereafter, the court again sentenced Defendant to life imprisonment without the possibility of parole. The Fifth District Court of Appeal vacated Defendant’s sentence, concluding that the only sentence now available in Florida for a charge of capital murder committed by a juvenile was life with the possibility of parole after twenty-five years. The Supreme Court quashed the underlying decision and remanded the case for resentencing, holding that the proper remedy is to apply chapter 2014-220, Laws of Florida, to all juvenile offenders whose sentences are unconstitutional under Miller. View "Horsley v. State" on Justia Law

When he was seventeen years old, Defendant was tried as an adult and convicted of, among other nonhomicide offenses, three counts of sexual battery while possessing a weapon, two counts of robbery, and one count of kidnapping. After Defendant was initially sentenced to life imprisonment plus sixty years, in light of the recently issued Graham v. Florida decision, the trial court resentenced Defendant to concurrent thirty-year sentences for the sexual batteries. The remaining sentences were to run consecutively. The Fifth District Court of Appeal affirmed, holding that Graham does not apply to term-of-years prison sentences because such sentences do not constitute life imprisonment. The Supreme Court quashed the decision below and remanded for resentencing, holding (1) the constitutional prohibition against cruel and unusual punishment under Graham is implicated when a juvenile nonhomicide offender’s sentence does not afford any meaningful opportunity to obtain release based on demonstrated maturity and reform; and (2) because Defendant’s aggregate sentence did not afford him this opportunity, his sentence was unconstitutional under Graham. View "Henry v. State" on Justia Law

When Defendant was fourteen years old he pleaded guilty to attempted first-degree murder, attempted armed robbery, and aggravated battery. The trial court adjudicated Defendant guilty as charged and imposed prison terms of seventy years for the attempted murder conviction and twenty-five years for the attempted armed robbery conviction. Defendant appealed and filed a motion pursuant to Fla. R. Crim. P. 3.800(b)(2), arguing that, under the rationale of Graham v. Florida, his seventy-year prison sentence constituted cruel and unusual punishment. The trial court denied the requested relief. The First District Court of Appeal affirmed, holding that Graham did not apply in Defendant’s case because he did not face a life sentence without the possibility of parole. The Supreme Court quashed the First District’s decision to the extent it affirmed the seventy-year prison sentence and remanded to Defendant’s sentencing court, holding that Defendant’s seventy-year prison sentence did not provide a meaningful opportunity for future release, and therefore, the sentence was unconstitutional in light of Graham. View "Gridine v. State" on Justia Law

After a jury trial, Defendant was convicted of second-degree murder and sentenced to forty-five years in prison. Defendant appealed, arguing that the trial judge erred in instructing the jury on the lesser included offense of manslaughter to require that to convict for that lesser offense the jury must find that Defendant intended to cause the death of the victim. The Court of Appeal agreed that the jury instruction on manslaughter was erroneous but rejected the claim of fundamental error because Defendant’s sole defense was misidentification, and therefore, Defendant failed to place any of the other elements of the offense in dispute, including the element of intent. The Supreme Court quashed the decision of the Court of Appeal, holding that fundamental error occurred that required a new trial where, because Defendant did not concede the intent by which the homicide was committed, proof on that issue remaining on the State and remained in dispute notwithstanding Defendant’s defense of misidentification. View "Griffin v. State" on Justia Law

Defendant was convicted of the first-degree murder of his father and sentenced to death. The Supreme Court affirmed the conviction and sentence, holding (1) the evidence supported the finding that the murder was committed in a cold, calculated, and premeditated manner and that the murder was motivated by financial gain; (2) the trial court erred in finding that the murder was especially heinous, atrocious, or cruel, but the error was harmless; (3) because Ring v. Arizona did not apply in this case, Defendant’s argument that Florida’s sentencing scheme is unconstitutional under Ring was denied; (4) the death sentence in this case was proportionate; and (5) the jury had competent, substantial evidence on which to find Defendant guilty of first-degree murder. View "Campbell v. State" on Justia Law

Defendant was convicted of first-degree murder, attempted first-degree murder, burglary of a dwelling with a battery therein, and attempted robbery with a deadly weapon. Defendant was sentenced to death for the murder. The Supreme Court affirmed Defendant’s convictions and sentences on appeal. Defendant later filed a motion to vacate judgment of convictions and sentences, alleging several claims of error. The postconviction court denied all claims. Defendant appealed the denial of his postconviction motion and also filed a petition for writ of habeas corpus, presenting two habeas claims. The Supreme Court affirmed the postconviction court’s order denying postconviction relief on all claims and denied habeas relief, holding that the postconviction court did not err in its judgment and that Defendant’s habeas claims were without merit. View "Miller v. State" on Justia Law

Defendant was charged with leaving the scene of a crash resulting in an injury under Florida’s hit-and-run statute. During trial, Defendant proposed a jury instruction that required the jury to find as an essential element that Defendant, the driver, had actual knowledge that he was involved in a crash. The trial judge denied the request and provided the standard jury instruction stating that the State must prove Defendant “knew or should have known” that he was involved in an accident. Defendant was found guilty and sentenced to two years in prison. The Fourth District Court of Appeal reversed, concluding that the jury instructions were incorrect because the law requires “actual knowledge of the accident.” The Supreme Court agreed with the Fourth District’s holding, holding that, for a defendant to be convicted under the state’s hit-and-run statute, the State must prove that the driver had actual knowledge of the crash, an essential element of the crime of leaving the scene of a crash. View "State v. Dorsett" on Justia Law

Defendant was convicted of first-degree murder, false imprisonment, armed robbery with a deadly weapon, and grand theft of a motor vehicle. Defendant was sentenced to death for the murder conviction. The Supreme Court affirmed the convictions but reversed and remanded the original sentencing order on the basis that it violated Campbell v. State. The trial court subsequently issued a second revised sentencing order that again sentenced Defendant to death. Defendant appealed, arguing that he was entitled to a new penalty phase because the second revised sentencing order did not comport with the state’s capital sentencing statutory scheme. The Supreme Court reversed the remanded the second revised sentencing order, holding that it impermissibly relied on a nonstatutory aggravating factor and contained cumulative errors. View "Oyola v. State" on Justia Law