Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of two counts of first-degree murder, one count of burglary, and one count of possession of a firearm by a convicted felon. The trial court sentenced Defendant to death for both murders. The Supreme Court affirmed the convictions and sentences, holding (1) the trial court did not err in denying Defendant's motion to disqualify the judge; (2) the trial court did not prejudicially err in its evidentiary rulings during the guilt phase of trial; (3) the trial court did not err in finding the murders were committed in a cold, calculated, and premeditated manner, without any pretense of moral or legal justification; (4) sufficient evidence supported Defendant's convictions; and (5) Defendant's death sentences were proportionate. View "Gregory v. State" on Justia Law

After waiving counsel, Defendant pled guilty to and was convicted of first-degree murder. Following the penalty phase, Defendant was sentenced to death and to terms of imprisonment for the related charges of burglary, sexual battery, and arson. The Supreme Court affirmed on direct appeal. Defendant subsequently filed a motion for postconviction relief. The circuit court summarily denied the motion. The Supreme Court affirmed, holding (1) the trial court and Defendant's standby counsel did not err in failing to order a competency evaluation before allowing him to plead guilty, as the record supported the conclusion that Defendant was competent; and (2) Defendant's claim that his death sentence violated the Eighth Amendment because he may be incompetent at the time of execution was not ripe for review. View "Barnes v. State" on Justia Law

Defendant was convicted in 1982 to capital sexual battery and sentenced to life imprisonment. The court of appeal affirmed Defendant's conviction and sentence. Since then, Defendant made many pro se filings in the Supreme Court that were devoid of merit or inappropriate for review in the Court. At issue in this case was a recent pro se habeas petition filed by Defendant seeking to challenge his conviction and sentence. The Supreme Court dismissed the petition as unauthorized under Baker v. State. The Court also retained jurisdiction and ordered Defendant to show cause why he should not be barred from further pro se filings related to that criminal case and why the Court should not determine his filing was frivolous. After Defendant responded, the Court concluded that Defendant failed to show cause why he should not be sanctioned. Accordingly, the Court found the current finding frivolous and ordered the clerk of court to reject any future pro se pleadings or filings submitted by Defendant. View "Myles v. Crews" on Justia Law

After a trial, Defendant was convicted of first-degree murder and sentenced to death. After the denial of his first request for postconviction relief, Defendant filed a successive motion for postconviction relief, asserting that newly discovered evidence from a new witness impeached the only witness who identified Defendant as leaving the crime scene immediately after the murder, and demonstrated that the State violated Brady v. Maryland and Giglio v. United States. The postconviction court summarily denied relief. The Supreme Court remanded the Brady and Giglio claims for an evidentiary hearing but affirmed the order denying the newly discovered evidence claim. The postconviction court held an evidentiary hearing on remand and again denied relief. The Supreme Court affirmed, holding (1) substantial evidence supported the postconviction court's finding that Defendant failed to show the State willfully suppressed favorable evidence in violation of Brady; and (2) the postconviction court correctly denied Defendant's claim that the State knowingly presented false testimony in violation of Giglio. View "Mungin v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and aggravated battery. The trial court sentenced Defendant to death for the murder. The Supreme Court affirmed Defendant's convictions and sentences, holding (1) the trial court did not abuse its discretion in admitting evidence of text messages sent from Appellant's cell phone to the victims; (2) the trial court did not err in finding that the murder was cold, calculated, and premeditated; (3) the trial court did not abuse its discretion in giving great weight to the finding that the murder was especially heinous, atrocious, or cruel; (4) the death sentence was proportionate in this case; (5) Florida's capital sentencing scheme does not violate Ring v. Arizona; and (6) competent, substantial evidence supported the jury's finding of first-degree murder beyond a reasonable doubt. View "Jean-Philippe v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. Defendant appealed, contending, among other things, that the trial court erred when it denied his motion to suppress his confession because, during his interrogation and before he confessed to the murder, he invoked his right to remain silent. The Supreme Court reversed the conviction and remanded for a new trial, holding (1) based on the totality of the circumstances, the police did not scrupulously honor Defendant's invocation of his right to remain silent; (2) there was not competent, substantial evidence supporting the trial court's finding that Defendant's confession was voluntary; and (3) this error was not harmless beyond a reasonable doubt. View "Deviney v. State" on Justia Law

The State charged Defendant with two drug-related offenses. Defendant rejected a twelve-year plea offer after being incorrectly advised that his maximum sentence was thirty years when, in fact, Defendant faced a maximum sentence of life in prison. After trial, Defendant was found guilty of simple sale of cocaine and possession of cocaine and was sentenced to thirty years imprisonment. The court of appeal affirmed, concluding that Defendant could not show prejudice because he ultimately received the same sentence as what he was incorrectly advised. Subsequent to the court of appeal's decision, the U.S. Supreme Court issued two decisions - Missouri v. Frye and Lafler v. Cooper - concerning ineffective assistance of counsel claims in which the defendant rejected a pea offer based on misadvice. In light of these two cases, the Florida Supreme Court receded from its decisions in Cottle v. State and Morgan v. State with respect to what a defendant must show in order to demonstrate prejudice. After clarifying what a defendant must show to demonstrate prejudice, the Court quashed the court of appeal's decision because it incorrectly analyzed the prejudice prong. Remanded. View "Alcorn v. State" on Justia Law

After a jury trial, Petitioner was convicted of first-degree murder under both premeditated and felony-murder theories. The trial court sentenced Petitioner to death. The Supreme Court affirmed Petitioner's conviction and sentence. Petitioner subsequently filed several motions for postconviction relief. This appeal concerned the denial of Petitioner's third successive motion for postconviction relief and a motion to vacate his death sentence or, in the alternative, a motion for an evidentiary hearing. Petitioner also filed a fifth state petition for writ of habeas corpus. The Supreme Court affirmed the circuit court's order dismissing Petitioner's motions, holding (1) Petitioner's claim of newly discovered evidence was without merit; (2) Petitioner's claim regarding his counsel on direct appeal was procedurally barred and without merit; and (3) Petitioner's claim of ineffective assistance of trial counsel during the penalty phase was procedurally barred. View "Van Poyck v. State" on Justia Law

After a jury trial in 2009, Defendant was convicted of second-degree murder and sentenced to life in prison. Defendant appealed, arguing that the trial court erred by instructing the jury on manslaughter by act and that the error was fundamental. The Second District Court of Appeal affirmed Defendant's conviction and sentence, concluding that the 2008 manslaughter by act instruction did not include an intent-to-kill element, which the Supreme Court found fundamentally erroneous in State v. Montgomery. However, the Second District certified that its decision conflicted with the with the decision of the First District in Riesel v. State. The Supreme Court quashed the decision of the Second District and approved the decision of the First District in Riesel, holding (1) the 2008 standard instruction for manslaughter by act erroneously required the jury to find Defendant intended to cause the death of the victim; and (2) the trial court fundamentally erred in giving the 2008 standard jury instruction in this case. Remanded for a new trial. View "Daniels v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and robbery with a deadly weapon. The trial court imposed a sentence of death. Defendant subsequently filed a postconviction motion, which was denied. Defendant appealed the denial of his motion and also filed a petition for writ of habeas corpus asserting ineffective assistance of appellate counsel. The Supreme Court affirmed, holding (1) the trial court did not err in finding Defendant's trial counsel was not ineffective for (i) deciding not to present the testimony of a mental health expert in the penalty phase to establish mental mitigation, (ii) failing to move for a change of venue, and (iii) failing to object to certain prosecutorial comments during the guilt phase closing argument; (2) Florida's capital sentencing scheme is constitutional; and (3) Defendant was not prejudiced by appellate counsel's failure to argue on direct appeal that the trial court improperly failed to assign weight to each mitigator and evaluate the relative weights of the aggravating and mitigating factors in its sentencing order. View "Taylor v. State" on Justia Law