Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of three counts of sexual battery and one count each of kidnapping, aggravated battery, and attempted robbery. Defendant was sentenced to life imprisonment for each sexual battery count and the kidnapping count. Defendant appealed, arguing that the trial court abused its discretion in refusing to give a curative instruction relating to statements the prosecutor made during voir dire. The Second District Court of Appeals found that the prosecutor’s remarks were improper but that there was “no reasonable possibility that the failure to give a curative instruction affected the verdict.” The Supreme Court quashed the Second District’s decision, holding that the prosecutor impermissibly commended during voir dire on Defendant’s constitutional right to remain silent, and the comments were not harmless beyond a reasonable doubt. View "Marston v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder, armed robbery with a deadly weapon, and arson. Appellant was sentenced to death for the murders. Appellant’s death warrant was signed and his execution set for March 20, 2014. Appellant filed several post-trial motions, all of which were denied. In this appeal, Appellant challenged the denial of his second successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, his motion to declare Fla. Stat. 922.052 unconstitutional, and his motion to dismiss his death warrant. The Supreme Court affirmed the postconviction court’s denial of relief on all three motions and denied Appellant’s motion for a stay of execution, holding that the postconviction court did not err in its judgment. View "Henry v. State" on Justia Law

Michelle McCall received prenatal medical care at a United States Air Force clinic as an Air Force dependent. McCall died after delivering her son as a result of severe blood loss. Petitioners filed an action against the United States under the Federal Tort Claims Act (FTCA). The federal district court found the United States liable under the FTCA. The court concluded that Petitioners’ economic damages amounted to $980,462 and Petitioners’ noneconomic damages totaled $2 million. However, the district court limited Petitioners’ recovery of wrongful death noneconomic damages to $1 million after applying Fla. Stat. 766.118, Florida’s statutory cap on wrongful death noneconomic damages based on medical malpractice claims. The district court subsequently denied Petitioners’ motion challenging the constitutionality of the wrongful death statutory cap. The Eleventh Circuit Court of Appeals affirmed the application of the statutory cap on noneconomic damages and held that the statute was not unconstitutional. The Florida Supreme Court accepted certification to answer questions of Florida law and answered by holding the statutory cap on wrongful death noneconomic damages provided in Fla. Stat. 766.118 violates the Equal Protection Clause of the Florida Constitution. View "Estate of McCall v. United States" on Justia Law

Appellant was convicted of first-degree murder and sentenced to death for killing a Florida Highway Patrol Trooper. The Governor set a death warrant for Appellant and scheduled his execution for February 26, 2014. This appeal concerned the denial of Appellant’s amended third successive motion for postconviction relief in which he challenged the Florida lethal injection protocol as applied to him. The Supreme Court affirmed the postconviction court’s denial of relief, holding (1) Appellant's suggestion that the Court depart from its established precedent as to the proper standard to apply to an Eighth Amendment challenge to the lethal injection protocol was unavailing; (2) the use of midazolam hydrochloride in the 2013 lethal injection protocol does not violate the Eighth Amendment; (3) the forced administration of vecuronium bromide does not violate Appellant’s Fourteenth Amendment rights under Sell v. United States because the holding of Sell does not apply to these circumstances; and (4) the postconviction court did not err in denying Appellant’s request to strike a witness’s testimony. View "Howell v. State " on Justia Law

After a jury trial, Appellant was convicted of the first-degree murder, kidnapping, and sexual battery of a nine-year-old and sentenced to death. After the Governor signed the warrant in this case Appellant filed numerous public records requests, a second successive motion for postconviction relief, and a request for a stay of execution. The circuit court denied Appellant's public records requests, his postconviction petition, and his request for a stay of execution. The Supreme Court affirmed in all respects, holding that the circuit court did not err in its rulings. View "Chavez v. State" on Justia Law

After a second jury trial, Appellant was convicted of first-degree murder and robbery and was sentenced to death. The Supreme Court affirmed the convictions but twice remanded for new penalty phases. Each time, the trial court sentenced Defendant to death. The Supreme Court affirmed the sentence of death. Appellant subsequently moved to vacate judgment of convictions and sentences, alleging ineffective assistance of counsel. The postconviction court denied all claims presented in Appellant’s motion to vacate. The Supreme Court affirmed, holding that the postconviction court did not err in denying Appellant’s claims of ineffective assistance of counsel during his second guilt phase trial and during his fourth penalty phase trial. View "Lebron v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder under the felony murder and premeditated theories in the deaths of Berthum Gibson and Keenethia Keenan and guilty of first-degree murder under the felony murder theory in the death of Desmond Robinson. Defendant was sentenced to death for the deaths of Gibson and Keenan. The Supreme Court affirmed the convictions and sentences, holding (1) the evidence was sufficient to support Defendant’s convictions under both the felony murder and premeditation theories; (2) the trial court did not err in giving additional weight to the felony murder aggravating circumstance; (3) Defendant’s death sentences were proportional; and (4) Defendant’s death sentences were not unconstitutional under Ring v. Arizona. View "Smith v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed on direct appeal. Defendant subsequently filed an amended motion to vacate his judgment and sentence, which the postconviction court denied. Defendant appealed and filed an accompanying petition for writ of habeas corpus. The Supreme Court affirmed, holding (1) the postconviction court did not err in finding Defendant competent to proceed in his postconviction proceedings; (2) the postconviction court did not err in denying Defendant’s claim of ineffective assistance of trial counsel during the penalty phase and voir dire; (3) the postconviction court did not err in summarily denying Defendant’s claim that trial counsel was ineffective for failing to file a motion for a change of venue; (4) Florida’s method of execution for lethal injection is constitutional; and (5) Defendant was not entitled to relief on his claim that his right against cruel and unusual punishment would be violated because he may be incompetent at the time of execution. View "Franklin v. State" on Justia Law

Defendant was convicted of first-degree murder, kidnapping, and sexual battery with great force. Defendant was sentenced to death. The Supreme Court affirmed Defendant’s convictions and sentence of death. Defendant subsequently filed a motion for postconviction relief, raising several allegations of error. The postconviction court denied the motion. The Supreme Court affirmed the postconviction court’s denial of relief and denied Defendant’s petition for a writ of habeas corpus, holding (1) trial counsel did not provide ineffective assistance; (2) Defendant was not entitled to relief on his claims relating to the State’s alleged use of Defendant’s co-defendant as a state agent and letters written between the co-defendant and Defendant; and (3) appellate counsel did not provide ineffective assistance. View "Johnson v. State" on Justia Law

In 1980, Appellant was convicted of first-degree murder and sentenced to death. After the Governor signed the death warrant in this case, Appellant filed a successive motion for postconviction relief seeking to vacate his judgments of conviction and sentence of death. Appellant also filed motions for disclosure of public records, discovery, and for a stay. The circuit court summarily denied the motions and postconviction claims. The Supreme Court temporarily relinquished jurisdiction for the purpose of holding an evidentiary hearing on the sole issue of the safety and efficacy of the new drug in the lethal injection procedure. After an evidentiary hearing, the circuit court rejected the claim that the use of midazolam hydrochloride as the first drug in the three-drug lethal injection protocol would result in a substantial risk of serious harm and, accordingly, held that the protocol was constitutional. The Supreme Court (1) affirmed the circuit court's order denying postconviction relief on the claims raised in Appellant's successive postconviction motion; but (2) reversed the circuit court's order denying Appellant's public records request for copies of his own inmate and medical records and ordered transmission of copies of those records to Appellant's counsel. View "Muhammad v. State" on Justia Law