Justia Civil Rights Opinion Summaries

The Supreme Court reversed the judgment of the postconviction court partially granting Defendant's motion to vacate his first-degree murder convictions and sentences of death pursuant to Fla. R. Crim. P. 3.851, holding that the postconviction court erred in granting a new penalty phase.Defendant pleaded guilty to two counts of first-degree murder and one count of attempted first-degree murder. After waiving a penalty-phase jury, Defendant was sentenced to death. Defendant later filed a postconviction motion under Fla. R. Crim. P. 3.851. The postconviction court summarily denied Defendant's four purely legal claims but granted a new penalty phase, ruling that counsel was deficient in investigating and presenting mitigating evidence, which prejudiced Defendant. The Supreme Court reversed, holding that Defendant failed to establish deficient performance in any respect. View "State v. Mullens" on Justia Law

The Supreme Court affirmed the decision of the postconviction court denying Defendant's motion to vacate his convictions and sentences, including three convictions for first-degree murder and three sentences of death, holding that Defendant was entitled to neither postconviction relief nor a writ of habeas corpus.In 2014, Defendant pleaded guilty to murdering his girlfriend and her two children. The trial court sentenced Defendant to death for each murder. Defendant later filed a motion for postconviction relief, which the trial court denied. Defendant appealed the court's decision and filed a petition for a writ of habeas corpus, raising two claims. The Supreme Court denied relief, holding (1) as to Defendant's petition for postconviction relief, Defendant failed to demonstrate error, deficiency, or prejudice as to any of his claims; and (2) as to Defendant's habeas corpus petition, Defendant was not entitled to relief on his claims. View "Covington v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and his sentence of death, holding that Defendant was not entitled to relief on his allegations of error.Defendant pleaded guilty to first-degree premeditated murder, after which the trial court sentenced him to death. Defendant challenged his sentence on appeal, arguing that the trial court failed to ensure that all available mitigation was developed and presented and failed to determine beyond a reasonable doubt that the aggravating factors were sufficient to justify death and outweighed the mitigating circumstances. The Supreme Court affirmed, holding (1) there was no fundamental error in the trial court's rulings regarding mitigation; (2) Defendant knowingly and voluntarily entered his plea, was made aware of the consequences, and was apprised of the constitutional rights he was waiving; and (3) Defendant's remaining claim was unavailing. View "Fletcher v. State" on Justia Law

The Supreme Court quashed the decision of the Third District Court of Appeal affirming Defendant's convictions of driving under the influence (DUI) causing damage to property or person and DUI causing serious bodily injury, holding that Defendant's dual convictions violated double jeopardy.On appeal, Defendant argued that his dual convictions arising from a single episode violated double jeopardy. The Third District affirmed, holding that principles of double jeopardy did not prohibit dual convictions and sentences for DUI property damages/bodily injury and DUI serious bodily injury arising from the commission of a single act. The Supreme Court reversed, holding (1) the criminal offenses of DUI causing damage to property or person and DUI causing bodily injury are degree variants of the same offense under Fla. Stat. 775.021(4)(b)2; and (2) Defendant's dual convictions for both offenses as to the same victim arising from a single episode violated the prohibition against double jeopardy. View "Velazco v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying the guilt-phase claims Kim Jackson raised in his motion for postconviction relief filed under Fla. R. Crim. P. 3.851 and denied Jackson's petition for a writ of habeas corpus, holding that Jackson was not entitled to relief.After a jury trial, Jackson was found guilty of first-degree murder and sentenced to death. The Supreme Court affirmed. Jackson subsequently filed a postcondition motion raising more than twenty claims for relief. The circuit court vacated Jackson's death sentence under Hurst v. State, 202 So. 3d 40 (Fla. 2016), and otherwise affirmed. The Supreme Court affirmed and denied habeas corpus relief, holding (1) a due process claim for preindictment delay requires a showing of substantial prejudice to the defendant and bad faith on the part of the State; (2) as to two of Jackson's claims of ineffective assistance of counsel this Court assumed deficient performance but found no prejudice; and (3) Jackson was not entitled to a writ of habeas corpus. View "Jackson v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Billy Sheppard Jr.'s motion to vacate his conviction of first-degree murder and denied Sheppard's petition for a writ of habeas corpus, holding that the circuit court properly denied postconviction relief for all guilt claims and that Sheppard failed to establish that he was entitled to habeas corpus relief.Sheppard was convicted of first-degree murder and sentenced to death. Sheppard later filed a motion to vacate his conviction and sentence under Fla. R. Crim. P. 3.851. The circuit court granted a new penalty phase but denied Sheppard's claims as to the guilt phase of his trial. Sheppard appealed, raising claims relevant to the guilt phase, and filed a petition for writ of habeas corpus raising two claims of ineffective assistance of counsel. The Supreme Court affirmed the circuit court's order and denied Sheppard's petition for writ of habeas corpus, holding that Sheppard was not entitled to relief on any of his claims. View "Sheppard v. State" on Justia Law

The Supreme Court affirmed Defendant's two first-degree murder convictions and two corresponding sentences of death, holding that Defendant was not entitled to relief on his allegations of error.After a trial, a jury found Defendant guilty of two counts of first-degree murder with a firearm. The jury rendered unanimous verdicts recommending a penalty of death on both murder counts, determining that the aggravating factors outweighed the mitigating circumstances. In this direct appeal, Defendant raised fifteen claims, including several challenges to the trial court's evidentiary rulings and to Florida's death penalty scheme. The Supreme Court affirmed Defendant's convictions for first-degree murder and his sentences of death, holding that Defendant failed to establish prejudicial error in any respect. View "Joseph v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court summarily denying Appellant's sixth successive motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, holding that the trial court did not err in summarily denying Appellant's postconviction motion.Appellant was convicted of first-degree murder, sexual battery, and burglary. The trial judge sentenced Appellant to death. In his sixth successive postconviction motion Appellant asserted two claims, including a claim under Brady v. Maryland, 373 U.S. 83 (1963). The trial court rejected both claims. The Supreme Court affirmed, holding that the trial court did not err in summarily denying Appellant's sixth postconviction motion. View "Booker v. State" on Justia Law

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

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