Articles Posted in Florida Supreme Court

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The Supreme Court affirmed the order of the postconviction court denying Appellant’s successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, in which Appellant claimed newly discovered evidence, ineffective assistance of counsel, Brady and Giglio violations, and violation of Hurst v. Florida, 136 S. Ct. 616, and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The postconviction court summarily denied Appellant’s claims. The Supreme Court affirmed the summary denial of Appellant’s successive motion for postconviction relief, holding (1) the evidence proffered by Appellant in support of his newly discovered evidence claim was not newly discovered evidence; and (2) Appellant’s remaining claims were without merit. View "Taylor v. State" on Justia Law

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The Supreme Court withdrew its opinion issued on January 24, 2018 in this case and substituted this opinion in its place, holding that the circuit court properly denied Appellant’s motion filed pursuant to Fla. R. Crim. P. 3.851. Appellant’s motion sought relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and this court’s decision on remand in Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court held that Appellant’s valid waiver of postconviction proceedings and counsel in 2008 precluded him from claiming a right to relief under Hurst. Moreover, even if Appellant’s postconviction waiver did not preclude him from raising a Hurst claim, Hurst would not apply retroactively to Appellant’s sentence of death. View "Trease v. State" on Justia Law

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The Supreme Court affirmed the circuit court’s denial of Appellant’s motion to vacate sentences of death under Fla. R. Crim. P. 3.851. The jury in Appellant’s case unanimously recommended death. In this successive postconviction motion, Appellant argued that his death sentences violated the Sixth Amendment in light of Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), and Hurst v. Florida, 136 S. Ct. 616 (2016) and that his death sentences violated the Eighth Amendment under Caldwell v. Mississippi, 472 U.S. 320 (1985), and must be vacated in light of Hurst, Hurst v. Florida, and Perry v. State, 210 So. 3d 630 (Fla. 2016). The circuit court denied relief. The Supreme Court affirmed, holding (1) the Hurst error in this case was harmless beyond a reasonable doubt; (2) Hurst-induced Caldwell claims against the standard jury instruction do not provide an avenue for Hurst relief; and (3) the circuit court properly denied Appellant’s Eighth Amendment Caldwell claim. View "Reynolds v. State" on Justia Law

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The Supreme Court affirmed the order of the postconviction court denying Appellant’s successive postconviction motion to vacate a sentence of death under Fla. R. Crim. P. 3.851. In his successive motion, Appellant claimed that his death sentence violated the Sixth Amendment in light of Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), and Hurst v. Florida, 136 S. Ct. 616 (2016) and violated the Eighth Amendment under Caldwell v. Mississippi, 472 U.S. 320 (1985). The Supreme Court affirmed the circuit court’s order summarily denying Appellant’s successive motion for postconviction relief, holding (1) any Hurst error in this case was harmless beyond a reasonable doubt; and (2) Appellant’s Caldwell claim was procedurally barred because it was raised and rejected on direct appeal. View "Taylor v. State" on Justia Law

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The Supreme Court affirmed Defendant’s convictions for murder and kidnapping but vacated his sentence of death and remanded for the imposition of a life sentence without eligibility for parole based on Defendant’s performance of his part of his agreement with the State. In the agreement, the State agreed not to seek the death penalty if Defendant agreed to lead investigators to the body. After the body was discovered, the State filed its notice of intent to seek the death penalty. The trial court subsequently denied Defendant’s motion to enforce the agreement. On appeal, Defendant argued that the trial court erred in denying his motion to prohibit the State from seeking the death penalty. The Supreme Court agreed, holding that once Defendant performed his end of the bargain with the State, the State was obligated to uphold its end of the agreement. As to Defendant’s remaining arguments concerning his conviction, the Supreme Court denied relief. The Supreme Court remanded the case with instructions for the trial court to reduce Defendant’s death sentence to life imprisonment without the possibility of parole. View "Johnson v. State" on Justia Law

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Defendant was entitled to a new penalty phase proceeding pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016) and Mosley v. State, 209 So. 3d 1248 (Fla. 2016) and based on his claim of ineffective assistance of penalty phase counsel. Defendant was convicted of first-degree murder and other crimes. The jury recommended a sentence of death for the murder by a vote of eleven to one. The trial court imposed a sentence of death. Defendant later filed a motion to vacate judgment of conviction and sentence pursuant to Fla. R. Crim. P. 3.851. The postconvcition denied all claims, concluding that penalty phase counsel was deficient but that Defendant was not prejudiced as a result. Defendant appealed and filed a petition for writ of habeas corpus seeking relief pursuant to Hurst v. Florida, 577 U.S. __ (2016). The Supreme Court affirmed the denial of postconvcition relief but granted the petition for writ of habeas corpus, vacated Defendant’s death sentence, and remanded, holding (1) trial counsel was deficient for failing to discover paternal neglect, paternal abuse, and the extent of paternal substance abuse, and the deficiency was prejudicial; and (2) the failure to require a unanimous verdict regarding the sentence of death was not harmless. View "Ellerbee v. State" on Justia Law

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The Supreme Court affirmed Defendant’s convictions for first-degree murder and other crimes but vacated his death sentence and remanded for a new penalty phase. After the penalty phase, the jury voted nine to three to recommend a sentence of death. The trial judge followed the jury’s recommendation. On appeal, Defendant raised seven allegations of error regarding guilt phase issues. The Supreme Court held that none of the issues warranted relief and that the evidence was sufficient to support Defendant’s first-degree murder conviction. The court, however, concluded that Defendant’s death sentence violated Hurst v. Florida, 577 U.S. __ (2016) and that the error in Defendant’s sentencing was not harmless beyond a reasonable doubt. View "Lebron v. State" on Justia Law

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In this appeal from an order entered on Defendant’s postconviction motion to vacate his conviction of first-degree murder and sentence of death and related convictions and sentences, the Supreme Court reversed the portion of the postconviction court’s order granting Defendant a new guilt phase but affirmed the portions of the postconviction court’s order granting Defendant a new penalty phase. The court held that the postconviction court (1) erred in granting relief on Defendant’s ineffective assistance of counsel claims regarding the voluntariness and reliability of Defendant’s written statement to the police detailing his involvement in the victim’s death and trial counsel’s guilt phase investigation; and (2) did not err in finding that trial counsel was ineffective for failing adequately to investigate and prepare for the penalty phase. As to Defendant’s cross-appeal, the Supreme Court held that the postconviction court (1) did not err to the extent that it denied four of Defendant’s postconviction claims; and (2) did not err in declining to conduct a cumulative error analysis. View "State v. Morrison" on Justia Law

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The Supreme Court in this case struck certain unconstitutional language from the 2013 amendments to Fla. Stat. 766.106 and 766.1065, which authorized secret, ex parte interviews to the list of informal discovery devices to which a medical malpractice claimant seeking redress must consent, holding (1) the right to privacy in the Florida Constitution attaches during the life of a citizen and is not retroactively destroyed by death, and this constitutional protection shields irrelevant, protected medical history and other private information from the medical malpractice litigation process; (2) in the wrongful death context, standing in the position of the decedent, the administrator of the decedent’s estate has standing to assert the decedent’s privacy rights; and (3) the Legislature unconstitutionally conditioned a plaintiff’s right of access to courts for redress of injuries caused by medical malpractice, whether in the wrongful death or personal injury context, on the claimant’s waiver of the constitutional right to privacy. View "Weaver v. Myers" on Justia Law

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The good-faith exception to the exclusionary rule did not apply to law enforcement officers’ warrantless search of Petitioner’s cell phone in this case. Petitioner was charged with one count of traveling to meet a minor to commit an unlawful sex act, one count of soliciting a minor to commit an unlawful sex act, and three counts of transmission of material harmful to a minor. At the time of Petitioner’s arrest, the arresting officers conducted a search incident to arrest and seized his cell phone. Petitioner filed a motion to suppress the evidence found on his cell phone, arguing that the warrantless search violated his Fourth Amendment rights. The trial court granted the motion to suppress, relying on the holding in Smallwood v. State (Smallwood II), 113 So. 3d 724 (Fla. 2013), that warrantless cell phone searches are unconstitutional. The First District Court of Appeal reversed, concluding that because the officers were relying in good faith on the holding in Smallwood v. State (Smallwood I), 61 So. 3d 448 (Fla. 1st DCA 2011), the good-faith exception to the exclusionary rule applied. The Supreme Court reversed, holding that, under Davis v. United States, 564 U.S. 229(2011), the good-faith exception did not apply in this case. View "Carpenter v. State" on Justia Law