Justia Civil Rights Opinion Summaries

Appellant was a prisoner under sentence of death. After the Supreme Court affirmed Appellant's death sentence on direct appeal. D. Todd Doss was appointed as counsel for Appellant for Appellant's postconviction proceedings. Thereafter, Appellant sought to discharge Doss as postconviction counsel and waive the postconviction proceedings. The circuit court found Appellant competent and issued an order discharging Doss and dismissing the proceedings. Doss, on behalf of Appellant, appealed. The Supreme Court affirmed, holding (1) Appellant was afforded constitutionally adequate competency, waiver of postconviction, and discharge of counsel proceedings; and (2) the circuit court did nor err in finding Appellant competent to waive postconviction proceedings and to discharge counsel. View "Gill v. State" on Justia Law

Appellant was convicted of first-degree murder, false imprisonment as a lesser included offense of kidnapping, armed robbery with a deadly weapon, and grand theft of a motor vehicle. A jury recommended a sentence of death. The trial court accepted that recommendation and sentenced Appellant to death. The Supreme Court affirmed the findings and underlying judgment of guilty in the trial court but reversed and remanded for the limited purpose of requiring the trial court to perform a new sentencing evaluation because the analysis of the mitigating circumstances in the trial court's sentencing order did not meet the requirements articulated in Campbell v. State. View "Oyola v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and armed robbery and sentenced to death. The Supreme Court affirmed Appellant's convictions and sentence, holding (1) Appellant's statement to police was properly admitted into evidence, and police did not violate the Fifth Amendment in obtaining the statement; (2) Appellant's confession was voluntary, and contrary to Appellant's contention, the confession was not coerced by detectives; (3) the trial court did not err in finding the aggravating factor of cold, calculated, and premeditated to be established in Appellant's capital murder prosecution; (4) the trial court did not err in finding that Appellant did not prove the mitigating factors of emotional abuse, sexual abuse, and remorse; (5) the trial court did not overlook any material evidence in considering the aggravating and mitigating factors; (6) Appellant's constitutional challenge to Florida's death sentencing scheme was without merit; (7) Appellant's sentence of death was proportionate; and (8) there was sufficient evidence to support Appellant's convictions. View "Martin v. State" on Justia Law

The State charged Defendant, who at the time was detained at a juvenile detention center, with one count of battery by detainee in violation of Fla. Stat. 784.03 and 784.082. Defendant moved to dismiss the charge, contending that a juvenile could not be lawfully charged with battery by detainee while detained in a juvenile detention facility. The trial court dismissed the charge based on its belief that it was bound to follow the first district court of appeal's decision in T.C. v. State, which held that the battery by detainee offense was inapplicable to juveniles held in juvenile facilities. The fourth district court of appeals reversed, noting that in the past it and the fifth district had affirmed a trial court order adjudicating a juvenile guilty of battery upon a fellow detainee. The Supreme Court affirmed, holding that a juvenile detention center qualifies as a "detention facility" for purposes of section 784.082, and thereby disapproving the first district's decision in T.C. View "Hopkins v. State" on Justia Law

Petitioner was convicted of the 1999 sexual battery and first-degree murder of an eighteen-year-old and sentenced to death. The Supreme Court affirmed his convictions and sentences. Petitioner subsequently appealed the denial of his motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851 and simultaneously petitioned for a writ of habeas corpus. The Supreme Court affirmed the postconviction court's denial of relief and denied Petitioner's habeas petition, holding (1) Defendant failed to carry his burden of demonstrating he was prejudiced by trial counsel's deficient performance in preparation for the penalty phase; (2) Rule 3.851, which imposes a one-year time limit for filing motions for postconviction relief, is not unconstitutional; (3) Florida's capital sentencing statute is not unconstitutional; and (4) certain omissions by his appellate counsel on direct appeal did not constitute ineffective assistance of appellate counsel. View "Douglas v. Tucker" on Justia Law

Defendant was charged with second-degree murder and was convicted as charged. The court of appeal affirmed. Defendant subsequently petitioned for writ of habeas corpus, arguing that his appellate counsel was ineffective for failing to raise a claim of fundamental error when the jury was instructed on manslaughter by intentional act as a lesser included offense. The third district court of appeal certified conflict with the decision of the first district court of appeal in Montgomery v. State. The Supreme Court stayed proceedings pending disposition of Montgomery. In Montgomery, the Court held that the use of the then-standard jury instruction on the lesser included offense of manslaughter by act constituted fundamental error in Montgomery's case because the instruction erroneously required the jury to find that the defendant intentionally caused the death of the victim. After the Court lifted the stay in the instant case, the Court quashed the decision under review and remanded the matter to the court of appeal for reconsideration upon application of its decision in Montgomery. View "Leggett v. State" on Justia Law

Defendant Joshua Lee Altersberger pled guilty to the first-degree murder of Florida Highway Patrol Sergeant Nick Sottile. The jury found two aggravating circumstances beyond a reasonable doubt: the murder was committed in a cold calculated, and premeditated manner; and the victim was a law enforcement officer engaged in the lawful performance of his official duties. The trial court followed the jury's recommendation and sentenced Defendant to death. Defendant appealed. The Supreme Court affirmed Defendant's conviction and sentence, holding (1) the trial court did not err in its finding that Sergeant Sottile's murder was cold, calculated, and premeditated; (2) Defendant's plea was knowingly, intelligently, and voluntarily entered into; and (3) the death penalty was proportionate in this case. View "Altersberger v. State" on Justia Law

Defendant was convicted of the first-degree murder of Officer Donna Fitzgerald. Fitzgerald's body was found in the paint room at Tomoka Correctional Institute (TCI). After Defendant, an inmate at TCI, was apprehended by TCI personnel, Defendant repeated, "I freaked out. I snapped. I killed her." The trial court imposed the sentence of death. The Supreme Court affirmed Defendant's conviction and sentence, holding (1) the trial court properly denied Defendant's motion to suppress his confessions; (2) the trial court did not err in admitting opinion testimony of the medical examiner regarding the sequence of wounds and position of the victim; (3) the trial court's finding of a certain aggravator was in error, but the error was harmless; (5) the death sentence was appropriate; and (6) Florida's death sentencing scheme is not unconstitutional under Ring v. Arizona.

Convicted of first-degree murder for causing the 2007 death of McKinness, Hampton was sentenced to death following the jury’s recommendation by a vote of nine to three. Hampton filed several motions seeking relief based on the allegation that one of the jurors was “under prosecution” at the time of his jury service. The trial court denied the motions. The Florida Supreme Court affirmed the conviction and sentence, rejecting challenges to the sufficiency of the evidence and the proportionality of the death sentence.

Defendant was sentenced to death for a drug-related 1988 murder. The Florida Supreme Court reversed the circuit court's denial of post-conviction relief based on a claim of ineffective assistance of counsel during the penalty phase. Counsel rendered ineffective assistance by failing to investigate, develop, and present available mitigating evidence that would have legally precluded the trial court from overriding the jury's life recommendation. The evidence in question concerned the abuse defendant endured at the hands of his father and the extremely negative influence his father had on his life and that from a young age he witnessed violent acts being committed against his mother and others, including witnessing others being killed.