Articles Posted in Florida Supreme Court

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The Supreme Court denied the petition for a writ of habeas corpus filed by Petitioner, a prisoner under a sentence of death for the murders of two victims. The court held (1) Petitioner was not entitled to a cumulative review of evidence supporting his alleged actual and legal innocence under due process principles; (2) Petitioner was not entitled to relief on his claim that he was denied his fundamental right to testify; and (3) Petitioner was not entitled to relief on his claim that he was unconstitutionally denied access to materials that may contain DNA evidence. View "Lambrix v. Jones" on Justia Law

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Law enforcement officers may detain the passengers of a vehicle for the reasonable duration of a traffic stop without violating the Fourth Amendment. Defendant was one of two passengers in a vehicle stopped for a faulty taillight and a stop sign violation. Defendant was subsequently arrested for violation of probation. During the search incident to arrest, cocaine was recovered from Defendant’s pocket. Defendant filed a motion to suppress, arguing that he was illegally detained during the traffic stop. The circuit court denied the motion. The court of appeal affirmed, ruling that “an officer may, as a matter of course, detain a passenger during a lawful traffic stop without violating the passenger’s Fourth Amendment rights.” The Supreme Court approved the decision below, holding that the seizure of Defendant did not violate the Fourth Amendment. View "Presley v. State" on Justia Law

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The Supreme Court affirmed Defendant’s conviction for first-degree murder but vacated his sentence of death and remanded for a new penalty phase. The court held (1) the evidence was sufficient to support Defendant’s conviction; (2) the trial court did not abuse its discretion in excluding evidence of the victim’s drug use; (3) the trial court did not abuse its discretion by not conducting an inquiry into counsel’s effectiveness pursuant to Nelson v. State, 274 So. 2d 256 (Fla. 4th DCA 1973); (4) Defendant’s claim of ineffective assistance of counsel was not cognizable on direct appeal; (5) competent, substantial evidence supported the trial court’s finding that Defendant was not intellectually disabled; but (6) in light of a ten-to-two jury recommendation for death, error pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016), occurred in this case, and the error was not harmless beyond a reasonable doubt. View "Glover v. State" on Justia Law

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The Supreme Court affirmed the postconviction court’s order denying Robert Peterson post-conviction relief as to the guilt phase of Peterson’s criminal trial and denied Peterson’s separate habeas petition. The court, however, concluded that Peterson was entitled to a new penalty phase under Hurst v. State, 202 So. 3d 40 (Fla. 2016). Peterson was convicted of first-degree murder and evidence tampering and was sentenced to death. The jury recommended death by a vote of seven to five. Peterson appealed the denial of his postconviction motion. The Supreme Court held (1) Peterson was not entitled to relief as to his ineffective assistance of guilt phase counsel claim; but (2) the Hurst error during Peterson’s penalty phase was not harmless beyond a reasonable doubt, warranting a new penalty phase proceeding. View "Peterson v. State" on Justia Law

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The trial court granted Defendant’s motion to suppress evidence found on his cell phone by arresting officers pursuant to a search incident to arrest, relying on the holding in Smallwood v. State, 113 Wo. 3d 724 (Fla. 2013) that warrantless cell phone searches are unconstitutional. The First District Court of Appeal reversed, relying on Davis v. United States 564 U.S. 229 (2011) to conclude that because the officers relied in good faith on the holding in Smallwood v. State, 61 So. 3d 448 (Fla. 1st DCA 2011), the appellate precedent at the time of the search, the evidence was not subject to the exclusionary rule based on the good-faith exception. The Supreme Court disapproved the First District’s decision and held that the good-faith exception to the exclusionary rule did not apply to the officers’ warrantless search of Defendant’s cell phone because the officers were not relying on the type of longstanding, thirty-year appellate precedent at issue in Davis, but rather, on a non-final, pipeline case still under active review in the Supreme Court at the time of the search. View "Carpenter v. State" on Justia Law

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Harrel Franklin Braddy was convicted of first-degree murder and other crimes. After a penalty phase, the jury recommended the death penalty by a vote of eleven to one. The trial court sentenced Braddy to death. The Supreme Court affirmed. Braddy then filed a motion for postconviction relief, asserting eight claims. The postconviction court denied Braddy’s claims. Braddy appealed the denial of postconviction relief and filed a petition for a writ of habeas corpus. The Supreme Court affirmed the postconviction court’s denial of relief for a new guilt phase and denied the claims in Braddy’s habeas petition with the exception of his claim for relief under Hurst v. Florida, 577 U.S. __ (2016), holding that Braddy was entitled to a new penalty phase in light of the nonunanimous jury recommendation to impose a death sentence and the fact that it could not be said that the failure to require a unanimous verdict was harmless. View "Braddy v. State" on Justia Law

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Michael Duane Zack, III was found guilty of the sexual assault, robbery, and first-degree murder of Ravonne Smith. After a penalty phase hearing, the jury recommended a sentence of death by a vote of eleven to one. The trial court followed the jury’s recommendation. This appeal concerned Zack’s second successive postconviction motion in which he raised a claim of intellectual disability based on Hall v. Florida, 572 U.S. __ (2014). The trial court summarily denied the motion. Zack appealed the denial of postconviction relief and also petitioned for habeas corpus relief. The Supreme Court held (1) with regard to Zack’s postconviction motion, the trial court did not err in summarily denying Zack an evidentiary hearing on his intellectual disability claim and in determining that Defendant did not satisfy the subaverage intellectual functioning prong; and (2) Zack was not entitled to relief under Hurst v. State, 202 So. 3d 40 (Fla. 2016) because Hurst does not apply retroactively to cases, such as Zack’s, that were final before the Supreme Court decided Ring v. Arizona, 536 U.S. 582 (2002). View "Zack v. State" on Justia Law

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Donte Jermaine Hall was convicted and sentenced to death for the murder of Anthony Blunt. The jury voted eight to four in favor of a death sentence for the murder of Blunt. The trial court followed the jury’s recommendation. Hall filed a motion for postconviction relief under Fla. R. Crim. P. 3.851. He appealed the denial of that motion and also petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of Hall’s postconviction guilt phase claims, denied the habeas guilt phase claims, but vacated his death sentence and remanded for a new penalty phase, holding (1) the trial court did not err in denying Hall’s ineffective assistance of trial counsel claim; (2) the trial court did not err in denying Hall’s ineffective assistance of appellate counsel claim; and (3) Hall’s death sentence violated Hurst v. Florida, 577 U.S. __ (2016), and the Hurst error was not harmless beyond a reasonable doubt. View "Hall v. State" on Justia Law

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Thomas Bevel was found guilty of two counts of first-degree murder. The jury recommended the death penalty by a vote of eight to four as to the murder of Garrick Springfield and by a unanimous vote of twelve to zero as to the murder of Phillip Sims. The trial court followed the jury’s recommendations. Bevel later filed a motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, raising ten claims. The postconviction court denied relief, including Bevel’s ineffective assistance of penalty phase counsel claim. Bevel appealed and filed a petition for a writ of habeas corpus, claiming ineffective assistance of appellate counsel and arguing that he was entitled to relief under Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court denied Bevel’s habeas petition but reversed the denial of postconviction relief, vacated Bevel’s death sentences, and remanded for a new penalty phase proceeding, holding (1) Bevel was entitled to Hurst relief for his death sentence for the murder of Springfield; (2) penalty phase counsel conducted an unreasonable mitigation investigation, and because Bevel met the prejudice prong under Strickland, his death sentence for the murder of Sims must be vacated; and (3) Bevel’s remaining claims of error were unavailing. View "Bevel v. State" on Justia Law

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The Supreme Court granted John Lee Hampton’s petition for a writ of habeas corpus, vacated Hampton’s sentence of death, and ordered that Hampton receive a new penalty phase proceeding in light of Hurst v. State. In addition, the Court affirmed the postconviction court’s order denying Hampton’s motion to vacate his conviction of first-degree murder and sentence of death to the extent it denied Hampton relief based upon his claim of ineffective assistance of guilt phase counsel and further affirmed the determination that Hampton was not intellectually disabled. The Court declined to address the remaining issues in Hampton’s appeal of the postconviction court’s order, which relate to penalty phase issues, due to its holding that the Hurst error during Hampton’s penalty phase proceedings was not harmless beyond a reasonable doubt. View "Hampton v. State" on Justia Law