Justia Civil Rights Opinion Summaries

Articles Posted in Florida Supreme Court
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The Supreme Court approved the decision of the First District Court of Appeal in this case, holding that Fla. Stat. 942.051(3), which prohibits raising an unpreserved claim of error on direct appeal absent a showing of fundamental error, precludes appellate review of unpreserved claims of ineffective assistance of trial counsel on direct appeal.Defendant was found guilty of first-degree murder. On appeal, Defendant argued that he received ineffective assistance of counsel. The First District affirmed Defendant's convictions and sentence and declined to address his claims of ineffective assistance because he did not preserve any of the errors he advanced on appeal and did not make a claim of fundamental error. The Supreme Court approved of the decision below, holding that the plain text of section 924.051 prohibits raising unpreserved error on direct appeal absent a showing of fundamental error. View "Steiger v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death, holding that Defendant's arguments on appeal were unavailing.Specifically, the Supreme Court held that the trial court did not abuse its discretion in granting Defendant's request for self-representation because (1) a competency hearing was not required; (2) substantial evidence supported the findings that Defendant's waiver of the right to counsel was knowing, voluntary, and intelligent under Faretta v. California, 422 U.S. 806; and (3) the trial court was not required to find that Defendant suffered from severe mental illness to the point that he was incompetent to conduct trial proceedings by himself. View "Noetzel v. State" on Justia Law

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The Supreme Court affirmed the judgment of the postconviction court denying Defendant's petition for postconviction relief as to the guilt phase of his trial and denied his petition for a writ of habeas corpus, holding that Defendant was not entitled to relief.Defendant was convicted of three counts of first-degree murder and sentenced to death for two of the murders. The Supreme Court affirmed. Defendant later filed a motion for postconviction relief, raising sixteen claims. The trial court granted in limited part Defendant's motion for postconviction relief as to a new penalty phase under Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court affirmed, holding (1) the postconviction court did not err in denying Defendant's motion for postconviction relief as to the guilt phase; and (2) Defendant failed to establish that he was entitled to a writ of habeas corpus. View "Smith v. State" on Justia Law

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The Supreme Court affirmed Defendant's judgments of conviction of first-degree murder and sentences of death, holding that there was no prejudicial error in the proceedings below.Defendant was convicted and sentenced to death for his role in a 2016 triple homicide. The Supreme Court affirmed the convictions and sentences, holding (1) certain prosecutorial comments challenged by Defendant did not constitute fundamental error; (2) the trial court did not err in permitting the use of a map as a demonstrative aid; (3) there was no error in the State's presentation of victim impact evidence; and (4) the evidence was sufficient to support the convictions. View "Alcegaire v. State" on Justia Law

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The Supreme Court affirmed the order of the postconviction court denying Gary Hilton's motion to vacate his conviction of first-degree murder and sentence of death and denied Hilton's petition for a writ of habeas corpus, holding that Hilton was not entitled to relief.Specifically, the Supreme Court held (1) as to Hilton's claims of ineffective assistance of counsel, Defendant's allegations of deficient performance were insufficient to satisfy Strickland, and the postconviction court did not err in denying Hilton's claim that he was entitled to relief under Hurst v. Florida, 577 U.S. 92 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016); and (2) as to Hilton's petition for writ of habeas corpus, some claims were procedurally barred and, as to his remaining claims, Hilton was not entitled to relief. View "Hilton v. State" on Justia Law

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The Supreme Court affirmed Defendant's judgment of conviction of first-degree murder and sentence of death, holding that Defendant failed to demonstrate error on the part of the trial court.Specifically, the Supreme Court held (1) the trial court did not commit fundamental error by failing to find beyond a reasonable doubt that sufficient aggravating circumstances existed and that those circumstances outweighed the mitigating circumstances; (2) there was no merit to Defendant's challenges to the trial court's handling of mitigating evidence; (3) Defendant's challenge to the constitutionality of the prior-violent-felony aggravator was unavailing; and (4) Defendant's guilty plea was voluntarily and knowingly given. View "Davidson v. State" on Justia Law

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The Supreme Court affirmed the order of the trial court summarily dismissing Defendant's successive motion for postconviction relief, holding that the trial court did not err.Defendant pleaded guilty to two counts of first-degree murder and was sentenced to death. The Supreme Court affirmed on direct appeal. When his convictions and sentences had been final for more than twenty-three years Defendant filed the instant successive postconviction motion under Fla. R. Crim. P. 3.851, raising five claims. The trial court summarily dismissed the successive motion. The Supreme Court affirmed, holding (1) the trial court did not err in dismissing four of Defendant's claims as untimely; and (2) Defendant's claim that his death sentences violated the Sixth and Fourteenth Amendments in light of Hurst v. Florida, 577 U.S. 92 (2016), was both untimely and without merit. View "James v. State" on Justia Law

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The Supreme Court affirmed Defendant's convictions for first-degree murder but reversed his sentence of death and remanded for the limited purpose of resentencing and a new sentencing order, holding that the trial court improperly relied on facts not in the record in sentencing Defendant to death.Specifically, the Supreme Court held (1) the trial court impermissibly relied on non record evidence from the trial of Defendant's codefendant in finding that Defendant was the shooter in this case and sentencing him to death; and (2) Defendant was not entitled to relief on his remaining claims of error. The Supreme Court remanded the case for the limited purpose of requiring the trial court to perform a new sentencing evaluation and provide a new sentencing order. View "Cruz v. State" on Justia Law

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The Supreme Court affirmed the sentence of death that was imposed at Defendant's resentencing for the first-degree murder of Seath Jackson, holding that Defendant's claims of error were unavailing.The Supreme Court previously affirmed Defendant's conviction for first-degree murder with a firearm but vacated his sentence of death and remanded for a new penalty phase based on Hurst v. State, 202 So. 3d 40 (Fla. 2016). After a new penalty phase, the judge again imposed a sentence of death. The Supreme Court affirmed, holding (1) the State was not precluded from seeking the death penalty; (2) Defendant's argument that the court erred in allowing evidence of post-death acts was not adequately preserved for review; (3) the circuit court did not abuse its discretion in assigning little or no weight to mental mitigation factors; (4) the circuit court properly considered Defendant's age and certain other mitigating circumstances; and (5) the death sentence was not disproportionate. View "Bargo v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction for first-degree murder and his sentence of death, holding that Defendant's claims on appeal failed.Specifically, the Supreme Court held (1) the trial court's failure to renew an offer of counsel before commencing the penalty phase did not constitute fundamental error because the trial court cured the error; (2) no error occurred as a result of the prosecutor's statement that he would ask the jury to return a recommendation of death; (3) a challenged guilt-phase instruction was in error, but the error was not fundamental; (4) Defendant waived his claim that a Fifth Amendment violation occurred; (5) the trial court did not err in instructing the penalty-phase jury; and (6) the evidence was sufficient to support the conviction. View "Allen v. State" on Justia Law