Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of the first-degree murders of two Clearwater residents and received two sentences of death. The Supreme Court affirmed the trial court's judgments of conviction and sentences of death, holding (1) Defendant's argument that his penalty phase counsel penalty provided ineffective assistance did not warrant relief on direct appeal, as ineffective assistance of counsel claims are not cognizable on direct appeal; (2) Defendant's death sentences were not unconstitutional because they were based on a seven-to-five bare majority recommendation by the jury; (3) the trial court did not commit error in suggesting to the State that it seek the prior capital felony aggravating circumstance; (4) the State's closing argument during the guilt phase did not warrant a new trial; (5) substantial evidence supported each of Defendant's convictions; and (6) Defendant's death sentences were proportional to similar cases where the Court affirmed the sentence of death. View "Robards v. State" on Justia Law

In 1972, Petitioner was convicted and sentenced to life imprisonment for committing capital sexual battery. In a separate case, Petitioner pled guilty to of unlawful use of a motor vehicle. From 1992 forward, Petitioner filed multiple pro se extraordinary writ petitions and other proceedings with the Supreme Court seeking relief from his conviction and sentence. None of the petitions for relief was granted. In the instant case, Petitioner filed pro se petitions for writs of habeas corpus. The Court dismissed the petitions as unauthorized pursuant to Baker v. State and found them to be frivolous proceedings. Because the petitions were dismissed as unauthorized and also were the ninth and tenth pro se proceedings initiated by Petitioner in the Court, and because Petitioner failed to show cause why he should not be sanctioned, the Court instructed the clerk of court to reject any future pleadings, petitions or filings submitted by Petitioner related to his criminal cases. View "McCutcheon v. State" on Justia Law

Defendant was convicted of first-degree murder and robbery with a deadly weapon. Defendant appealed, arguing that the trial judge erred in refusing to allow Defendant to call a witness despite defense counsel's determination that calling the witness would not be of benefit to Defendant's case. The Fourth District court of appeal held that determining which witnesses should be called by the defense is not a fundamental decision to be made by the defendant himself, and therefore, the trial court did not err in its judgment. The Fourth District subsequently certified conflict with the Fifth District's decision in Cain v. State. The Supreme Court (1) approved the decision of the Fourth District in this case and disapproved the decision of the Fifth District in Cain, holding that defense counsel has the final authority as to whether or not the defense will call a particular witness to testify at the criminal trial; and (2) receded from its decision in Blanco v. State to the extent it held that the ultimate decision rests with the defendant as to the presentation of witnesses. View "Puglisi v. State" on Justia Law

Petitioner was convicted under Fla. Stat. 790.19 for shooting into an unoccupied vehicle. The trial court determined Petitioner qualified as a prison releasee reoffender (PRR) under the forcible felony catch-all provision of the PRR statute and thus sentenced him to a prison term of fifteen years for the conviction. Petitioner filed a motion for postconviction relief disputing the validity of his sentence, claiming that his conviction was not a qualifying felony under the forcible felony catch-all provision of the PRR statute. The trial court denied the motion, and the fourth district court of appeal affirmed. The court, however, certified conflict with the first district's decision in Crapps v. State. The Supreme Court (1) approved the fourth district's decision, finding that the offense of shooting into an occupied vehicle necessarily involves the use or threat of physical force or violence against an individual, and therefore, qualifies as a forcible felony under the catch-all provision of the PRR statute; and (2) disapproved the opinion in the conflicting case of Crapps. View "Paul v. State" on Justia Law

After Defendant, an inmate, committed several sexual offenses in Florida and Georgia, the state attorney initiated civil commitment proceedings against him under the Jimmy Ryce Act. Almost four years later, Defendant, who was still in custody, filed a motion to dismiss the commitment petition, arguing that he was not in lawful custody at the time commitment proceedings were initiated because his sentence had expired due to postconviction credit for time previously served. The circuit court denied the motion to dismiss based on its determination that Defendant was in lawful custody when commitment proceedings were initiated. The district court dismissed the commitment petition and ordered the immediate release of Defendant from custody, concluding that the circuit court did not have jurisdiction to adjudicate the commitment petition because Defendant was not in lawful custody when the State initiated commitment proceedings. The Supreme Court approved the district court's decision, holding that Defendant was not in lawful custody at the time the commitment procedures were initiated because his incarcerative sentence had already expired. View "State v. Phillips" on Justia Law

Defendant was convicted and sentenced to death for the kidnapping and murder of a ten-year-old. The Supreme Court affirmed Defendant's conviction on direct appeal but remanded for resentencing. After resentencing, when Defendant was again sentenced to death, the Supreme Court affirmed Defendant's sentence. Defendant filed several postconviction motions, which were denied. Defendant filed the instant motion to vacate sentence and requested certain public records after his execution date was set. The circuit court summarily denied relief on all claims. Defendant appealed and filed a petition for a writ of habeas corpus. The Supreme Court affirmed and denied habeas corpus relief, holding (1) the majority of Defendant's claims were without merit; (2) the circuit court properly denied Defendant's records requests because the requested records were not relevant to a colorable claim; and (3) Defendant's petition for habeas corpus was untimely. View "Mann v. State" on Justia Law

Defendant was convicted of attempted murder, among other crimes, and was sentenced to various terms of imprisonment, including a fifty-five-year term. Defendant's convictions and sentences were affirmed on appeal. After unsuccessfully making a number of filings in the Supreme Court challenging his convictions and sentences, Defendant filed a pro se petition for writ of mandamus with the Court. Because the petition filed in this case was without merit, and because Defendant submitted multiple other meritless filings seeking relief relating to his criminal case that demonstrated an ongoing pattern of abuse of the judicial process, the Court (1) instructed the clerk of court to reject any filings submitted by Defendant relating to his criminal court case; and (2) found Defendant's current petition to be frivolous and directed the clerk of court to forward a copy of this opinion to the Department of Corrections' institution or facility where Defendant was incarcerated. View "Nelson v. Crews" on Justia Law

After a jury trial, Defendant was convicted of kidnapping and first-degree murder. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant's convictions and sentence, holding (1) the trial judge did not err in admitting statements Defendant made to law enforcement because the statements did not constitute similar fact or collateral crime evidence and were otherwise relevant and admissible to establish premeditation; (2) because Defendant's expert testimony opened the door for a witness to testify about allegations of Defendant's past criminal conduct, the trial court properly admitted the testimony and properly excluded the witness from the sequestration rule; (3) substantial, competent evidence supported the trial court's fining that certain aggravating circumstances applied in Defendant's case; (4) the trial court properly rejected the lack of capacity mitigating factor; (5) the evidence was sufficient to support the convictions; and (6) the imposition of the death sentence in this case was proportionate when compared to other death sentences the Court has upheld. View "Hilton v. State" on Justia Law

Defendant was convicted of first-degree murder and kidnapping and sentenced to death for the first-degree murder and to fifteen years' imprisonment for kidnapping. The Supreme Court affirmed on direct appeal. Defendant subsequently filed a motion for postconviction relief. Following an evidentiary hearing, the circuit court denied postconviction relief on all claims. Defendant appealed the circuit court's denial of postconviction relief and also petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of Defendant's postconviction motion and denied his habeas petition, holding (1) the circuit court did not err in concluding that Defendant's postconviction claims were either procedurally barred, conclusively refuted by the record, facially or legally insufficient as alleged, or without merit as a matter of law; and (2) Defendant's counsel provided effective assistance, and therefore, Defendant's claims for habeas relief failed. View "Conahan v. State" on Justia Law

Plaintiff, the personal representative of the estate of Charlotte Douglas, filed a complaint against cigarette companies and industry organizations for damages on claims based on Charlotte's smoking-related death. After a jury trial, Plaintiff was awarded $2.5 million in damages. At issue on appeal was whether the trial court erred in the application of the Phase I findings in the class action case Engle v. Liggett Group, Inc. Charlotte was a member of the Engle class. The court of appeal affirmed, concluding that Plaintiff did not prove legal causation on his negligence theory but did prove legal causation on his strict liability claim. Although the court of appeal rejected Defendants' argument that applying res judicata to the findings violated their due process rights, it certified the due process question to the Supreme Court. The Court approved of the court of appeal's decision affirming the general verdict for Plaintiff based on strict liability but disapproved the court's rejection of negligence as a basis for the general verdict because the court's analysis required causation instructions and findings beyond those required by Engle. In addition, the Court answered that accepting as res judicata the eight Phase I findings approved in Engle did not violate Defendants' due process rights. View "Philip Morris USA Inc. v. Douglas" on Justia Law