Justia Civil Rights Opinion Summaries

Defendant was convicted and sentenced to death for the first-degree murder of an eleven-year-old girl. The Supreme Court affirmed the conviction and sentence. This appeal concerned Defendant’s amended successive Fla. R. Crim. P. 3.850 motion in which Defendant alleged four claims. The trial court summarily denied all claims. The Supreme Court affirmed the denial of one claim but remanded for an evidentiary hearing on the remaining claims. On remand, the trial court again denied all claims. The Supreme Court affirmed, holding (1) Defendant failed to establish a Giglio violation; (2) Defendant failed to establish a Brady violation, and Defendant’s ineffective assistance of trial counsel claim, pled as an alternative to his Brady claim, was procedurally barred; and (3) because newly discovered DNA evidence was not of such a nature that it would probably produce an acquittal on retrial, relief on Defendant’s newly discovered DNA evidence claim was properly denied. View "Rivera v. State" on Justia Law

After a jury trial, Defendant was found guilty of manslaughter with a firearm, attempted home invasion robbery with a firearm, and armed burglary. Prior to sentencing, the State informed the trial court that dual convictions for attempted home invasion robbery and armed robbery presented double jeopardy concerns. The parties subsequently debated as to which conviction should be vacated. The trial court accepted the position of the State and vacated the attempted home invasion robbery conviction, which carries a lesser sentence. The Second District Court of Appeal concluded that the lesser offense of armed burglary should have been vacated. The Supreme Court approved the decision below, holding that when a defendant is found guilty of two offenses and adjudication of the defendant as guilty for both offenses would violate double jeopardy protections, the lesser offense as defined by Pizzo v. State should be vacated. View "State v. Tuttle" on Justia Law

Tai Pham was convicted of first-degree murder, attempted first-degree murder, armed kidnapping, and armed burglary. The trial court entered a sentence of death. The Supreme Court affirmed the convictions and sentences. Pham later filed a motion to vacate judgment of conviction and sentence of death, raising several claims. The circuit court summarily denied some claims and held an evidentiary hearing on the remaining claims. Thereafter, the court denied relief. Pham appealed and also filed a petition for a writ of habeas corpus. The Supreme Court affirmed, holding (1) Pham failed to establish that he received ineffective assistance of counsel during either the guilt or the penalty phase; and (2) appellate counsel likewise did not provide ineffective assistance. View "Pham v. State" on Justia Law

Appellant, a prisoner under a sentence of death for whom a death warrant had been signed, filed a successive motion for postconviction relief raising an as-applied challenge to Florida’s lethal injection protocol based on his allegation that he suffers from the medical condition porphyria. The circuit court denied Appellant’s claim without an evidentiary hearing. Appellant appealed and produced an affidavit by a physician stating that, in the physician’s expert medical opinion, a substantial risk existed that the use of midazolam hydrochloride as the first drug of Florida’s lethal injection protocol would cause Appellant “extreme or excruciating pain.” In light of these allegations, the Supreme Court relinquished jurisdiction to the circuit court. After a hearing, the circuit court denied Appellant’s claim. The Supreme Court affirmed, holding that Appellant failed to demonstrate that Florida’s lethal injection protocol, as applied to him, violated the Eighth Amendment because he did not show that allegedly suffering from porphyria creates a “substantial risk of serious harm” upon the injection of midazolam. View "Davis v. State" on Justia Law

Appellant was convicted after a jury trial for the first-degree murders of an elderly couple, whom he cut and stabbed. Sentences of death were imposed for both murders, but the case returned to the circuit court. After a new penalty phase, Appellant was sentenced to death for only one murder. The Supreme Court affirmed Appellant's sentence of death. Appellant sought postconviction relief, alleging ineffective assistance of counsel. After an evidentiary hearing, the postconviction court concluded that Appellant was entitled to a new penalty phase trial. The Supreme Court reinstated Appellant's sentence of death, holding that Appellant was not entitled to any relief due to ineffective assistance of counsel under the Strickland v. Washington standard. View "State v. Woodel" on Justia Law

Defendant was charged with drug trafficking and possession after the vehicle he was driving was stopped by a deputy sheriff who had noticed an inconsistency between the actual color of the vehicle and the color indicated on the vehicle’s registration. Defendant moved to suppress the results of the stop as products of an unlawful, warrantless search. The trial court denied the motion to suppress, concluding that the vehicle was legally stopped for investigative purposes and that the odor of marijuana emanating from inside the vehicle gave the officer probable cause to conduct a search. Defendant was subsequently convicted. The district court reversed the denial of Defendant’s motion to suppress, concluding that a color discrepancy alone does not provide reasonable suspicion for an investigatory stop. The Supreme Court affirmed, holding that a color discrepancy, standing alone, does not justify initiating a stop to determine if the law has been violated. View "State v. Teamer" on Justia Law

After a jury trial, Richard England was found guilty of first-degree premeditated murder and felony murder and robbery with a deadly weapon. The trial court sentenced Petitioner to death. England later filed a petition for postconviction relief, alleging ineffective assistance of counsel. The postconviction court denied relief on all claims. Petitioner appealed and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of postconviction relief, holding that the postconviction did not err in concluding that counsel provided constitutionally effective assistance during both the guilt phase and penalty phase of trial. The Court also denied habeas relief, holding that England failed to establish that appellate counsel was ineffective, and the remainder of his claims were procedurally barred or without merit. View "England v. State" on Justia Law

Appellant was convicted of first-degree murder, attempted first-degree murder, and related crimes. The jury recommended that Appellant be sentenced to death, and the judge followed the jury’s recommendation. On appeal, the Supreme Court vacated Appellant’s death sentence based on the cumulative effect of errors made during the penalty phase of the trial. Following a new penalty phase, the trial court again sentenced Appellant to death. The Supreme Court upheld the trial court’s imposition of the death penalty on resentencing, holding (1) the trial court did not abuse its discretion in allowing the State’s strikes of two African American venirepersons; (2) the trial court did not abuse its discretion in allowing the State to introduce the severed fingertip of one of the victims into the new penalty phase; (3) the prosecutor engaged in improper arguments, but the errors were harmless; and (4) the death sentence in this case was appropriate. View "Poole v. State" on Justia Law

After a jury trial, Charles Peterson was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed the conviction and sentence. Peterson subsequently filed a postconviction motion in the circuit court, alleging ineffective assistance of counsel. The postconviction court denied relief. Peterson appealed the denial of his postconviction motion and also petitioned for a writ of habeas corpus, claiming that his appellate counsel provided ineffective assistance. The Supreme Court affirmed the postconviction court’s denial of relief and denied Peterson’s petition for a writ of habeas corpus, holding (1) Peterson’s claims that his trial counsel should have challenged certain jurors for cause and failed to effectively use peremptory challenges were without merit; (2) trial counsel was not ineffective for failing to challenge in- and out-of-court identifications; and (3) appellate counsel was deficient for providing incorrect information to the Court, but appellate counsel’s misstatement did not compromise the appellate process to such a degree as to undermine confidence in the correctness of the result. View "Peterson v. State" on Justia Law

Appellant murdered an eleven-year-old girl while on duty as a police officer. After a jury trial, Appellant was convicted of sexual battery and first-degree murder. The trial court sentenced Appellant to death after finding two aggravating factors. The Supreme Court affirmed Appellant’s convictions and sentences on appeal. This appeal concerned the circuit court’s order summarily denying Appellant’s successive motion for postconviction relief in which Appellant claimed, among other things, that newly discovered evidence demonstrated that an FBI analyst’s testimony at trial regarding hair evidence was erroneous. The Supreme Court affirmed, holding (1) because Appellant’s successive motion constituted relitigation of the same hair-analysis issues that Appellant previously raised, without success, he was not entitled to any relief; and (2) the postconviction court did not err in denying relief on Appellant’s remaining claims. View "Duckett v. State" on Justia Law