Justia Civil Rights Opinion Summaries

Butler was convicted of first-degree murder and sentenced to death for the 1997 murder of his former girlfriend. The Florida Supreme Court affirmed the conviction and death sentence on direct appeal. Butler filed a motion to vacate his conviction and death sentence pursuant to Florida Rule of Criminal Procedure 3.851. The post-conviction court held three evidentiary hearings and denied relief. The Florida Supreme Court affirmed, rejecting claims that appellate counsel provided ineffective assistance by failing to file a petition for certiorari with the U.S. Supreme Court; appellate counsel provided ineffective assistance by abandoning the claim that a witness was incompetent to testify at trial; Florida’s lethal injection protocol constitutes cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments; and Butler’s right against cruel and unusual punishment will be violated because he may be incompetent at the time of execution.

Petitioner sought review of the Third District's summary dismissals of his unfair labor practice (ULP) claim. The court concluded that because it found that the actions alleged in petitioner's claim were sufficient to establish a prima facie violation of Florida Statute 447.501, the court concluded that the Third District incorrectly affirmed the Public Employees Relations Commission's dismissal of petitioner's charges; the totality of the circumstances alleged in petitioner's charge were sufficient to demonstrate prima facie evidence that he suffered from an adverse employment action; petitioner's allegations regarding his transfer provided sufficient evidence of adverse employment action to survive summary dismissal; and petitioner sufficiently alleged a causal link between the protected activity and the adverse employment action.

Raymond Bright was convicted of two counts of first-degree premeditated murder and sentenced to death for the murders. The Supreme Court affirmed the convictions and sentences, holding (1) sufficient evidence existed in the record for the jury to convict Bright of first-degree premeditated murder; (2) the prosecutor did not improperly comment on Bright's right to remain silent, and the trial court did not abuse its discretion when it denied Bright's motion for a mistrial; (3) the trial court erred when it found and weighed as two separate aggravating circumstances Bright's prior felony conviction, but the improper double finding of the prior violent felony aggravating circumstance constituted harmless error; (4) the trial court did not abuse its discretion in finding and affording the aggravating circumstance that the murder was especially heinous, atrocious, or cruel, great weight; and (5) the sentences imposed by the trial court were proportionate.