Justia Civil Rights Opinion Summaries

Defendant was convicted of first-degree murder and sentenced to death. With a minor exception, the Supreme Court denied Defendant's requests for postconviction relief and his petitions for writs of habeas corpus. In this postconviction action, Defendant filed a motion requesting postconviction DNA testing on six items collected by law enforcement in connection with the investigation of the victim's murder. Of these items, the State was only able to locate one of them. The circuit court summarily denied Defendant's motion. The Supreme Court affirmed, holding that there was no reasonable probability that Defendant would have been acquitted or received a lesser sentence if DNA evidence from any of the requested items had they been admitted at his trial. View "Jackson v. State" on Justia Law

Defendant pled guilty to several crimes, including grand theft and first-degree felony murder. The trial court imposed the death sentence. The Supreme Court affirmed Defendant's convictions but vacated his sentence and remanded for a new penalty phase. On remand, the trial court again sentenced Defendant to death. The Supreme Court affirmed. Defendant subsequently filed an amended motion for postconviction relief, which the trial court denied after a hearing. Defendant appealed and filed a petition for writ of habeas corpus. The Supreme Court affirmed, holding, inter alia, (1) Defendant failed to show his counsel was constitutionally deficient; (2) the postconviction court did not abuse its discretion in denying Defendant's motion to disqualify the postconviction court's judge; and (3) appellate counsel provided effective assistance. View "Farr v. State" on Justia Law

Two decisions of the Third District Court of Appeal were before the Supreme Court here. In the first case (Public Defender), the Public Defender for the Eleventh Judicial Circuit filed motions in several criminal cases seeking to be relieved of the obligations to represent indigent defendants in non-capital felony cases. The trial court permitted the Public Defender to decline appointments in future third-degree felony cases. The court of appeal reversed. In the second case (Bowens), an assistant public defender filed a motion to withdraw from representing a defendant, alleging that his excessive caseload created a conflict of interest. The circuit court granted the motion, but the court of appeal reversed. The Supreme Court (1) quashed the court of appeal's decision in Public Defender and remanded, holding (i) aggregate/systemic motions to withdraw are appropriate where there is an office-wide or widespread problem as to effective representation, and (ii) the Public Defender demonstrated cause for withdrawal in this case; and (2) quashed in part and affirmed in part the decision in Bowens, holding that Fla. Stat. 27.5303(1)(d) is facially constitutional but should not preclude a public defender from filing a motion to withdraw based on excessive caseload or underfunding that would result in ineffective representation of indigent clients. View "Public Defender, Eleventh Judicial Circuit of Fla. v. State" on Justia Law

Defendant pleaded guilty to two counts of first-degree murder and was sentenced to death in 1998 on both murder counts. The Supreme Court affirmed Defendant's convictions and death sentences. Defendant subsequently filed a postconviction motion and a number of amended motions. Defendant also filed a motion to withdraw his guilty plea. In 2008, the trial court granted Defendant a new penalty phase proceeding based on the claim of ineffective assistance of counsel during the penalty phase but denied the remaining claims and Defendant's motion to withdraw his guilty plea. Defendant appealed and also petitioned the Supreme Court for a writ of habeas corpus, claiming his death sentence was disparate and disproportionate based on newly discovered evidence. The Supreme Court (1) affirmed the trial court's order denying relief on the claims relating to Defendant's guilty plea and an alleged Brady violation and granting relief on the claim of ineffective assistance of counsel in the penalty phase; and (2) denied Defendant's petition for habeas relief, holding that the claim in the petition should have been raised in the postconviction motion at the trial court and was therefore procedurally barred. View "Griffin v. State" on Justia Law

Defendant was convicted of first-degree murder and sexual battery and sentenced to death. The Supreme Court affirmed Defendant's convictions and death sentence on direct appeal. Defendant subsequently filed a several post-conviction motions, which were ultimately unsuccessful. After the governor set a date for Defendant's execution, Defendant filed a successive postconviction motion, raising four claims. The circuit court summarily denied relief on all claims. The Supreme Court affirmed, holding (1) Defendant's claim that his mental illness should exempt him from execution was untimely and procedurally barred; (2) Defendant's claim that the death warrant selection process was arbitrary, thus rendering the death penalty unconstitutional, was without merit; (3) Defendant's claim that the clemency process he received was conducted in an arbitrary and capricious manner was without merit; and (4) Defendant's claim that adding execution to the "inordinate length of time" he spent on death row would constitute cruel and unusual punishment was without merit. View "Carroll v. State" on Justia Law

After a jury trial, Defendant was convicted of the 2001 first-degree murder of his wife. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant's conviction and sentence. Defendant subsequently filed a motion for postconviction relief, raising several claims. The circuit court denied relief. The Supreme Court affirmed, holding that the postconviction court correctly denied relief on Defendant's claims of ineffective assistance of trial counsel, as (1) counsel's failure to investigate and present evidence that Defendant had organic brain damage did not undermine confidence in the sentence; (2) counsel was not constitutionally deficient regarding the child witnesses who testified at Defendant's trial; and (3) counsel's failure to present evidence regarding the registration of the gun used in the homicide did not undermine confidence in Defendant's sentence; and (4) counsel made a reasonable strategic decision to have Defendant wear jail clothing during the penalty phase. View "Rodgers v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, armed burglary, extortion, three counts of attempted murder, five counts of armed kidnapping, and four counts of armed robbery. Defendant was respectively sentenced to death and multiple terms of imprisonment. The Supreme Court later vacated Defendant's convictions and sentences on the attempted murder charges. Defendant subsequently filed a motion to vacate his first-degree murder conviction and sentence of death, raising several claims of ineffective assistance of counsel. The postconviction court denied relief on Defendant's claims. The Supreme Court affirmed, holding that, even assuming trial counsel's alleged deficiencies, they did not so affect the fairness and reliability of the proceeding that confidence in the outcome was undermined. View "Williamson v. State" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant's conviction and death sentence on direct appeal. Defendant subsequently filed a motion for postconviction relief. The trial court denied the motion after an evidentiary hearing. The Supreme Court remanded for a new evidentiary hearing, after which the circuit court issued an order denying postconviction relief on all claims. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus. The Court affirmed the denial of Defendant's motion for postconviction relief and denied his habeas petition, holding (1) the State did not commit Brady v. Maryland violations during trial or violate Giglio v. United States by failing to correct false or misleading testimony; (2) Defendant was given effective assistance of counsel at trial; (3) Defendant's claims that he was tried while incompetent were procedurally barred and without merit; and (4) because Defendant failed to demonstrate either deficient performance or prejudice on the part of his trial counsel, his habeas petition failed. View "Wickham v. State" on Justia Law

After a jury trial, Defendant was convicted of robbery and possession of a firearm by a convicted felon. The trial court sentenced Defendant to fifty years' incarceration on the robbery conviction and fifteen years' incarceration on the possession conviction. Defendant appealed the denial of his motion to suppress the search of information stored within his cell phone incident to his arrest. The court of appeal affirmed the trial court's decision in the admissibility of images found on Defendant's cell phone but certified a question to the Supreme Court as a matter of great public importance. The Supreme Court quashed the decision of the court of appeal and remanded, holding (1) the holding in United States v. Robinson does not allow a police officer to search through photographs contained within a cell phone that is on an arrestee's person at the time of a valid arrest; and (2) while law enforcement officers properly separated and assumed possession of a cell phone from Defendant's person during the search incident to arrest, a warrant was required before the information, data, and content of the cell phone could be accessed and searched by law enforcement. View "Smallwood v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended the death penalty by a vote of seven to five, and the trial court sentenced Defendant to death. The Supreme Court affirmed. Defendant subsequently filed a second amended initial motion for postconviction relief and supplemental addendum, presenting several claims. The postconviction court denied the motion and addendum. The Supreme Court affirmed the denial of Defendant's motion, holding (1) Defendant was afforded effective assistance of counsel at trial; (2) Defendant was not entitled to a claim of cumulative error because he failed to prevail on any individual claim of ineffectiveness; and (3) Defendant was not entitled to relief on his claims that Florida's death penalty violates Ring v. Arizona and is unconstitutional. View "McCoy v. State" on Justia Law