Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's convictions for first-degree murder and burglary of a dwelling with an assault and while armed with a firearm and Defendant's sentence of death, holding that this Court now joins federal courts and the majority of state courts in abandoning a special appellate standard to evaluate evidence on appeal in a wholly circumstantial case rather than in a case with some direct evidence.Defendant's convictions in this case were wholly based upon circumstantial evidence. The Supreme Court affirmed the convictions and sentence after discontinuing the use of the special standard of review previously applied to wholly circumstantial cases, holding (1) the standard of review now to be used in all cases where the sufficiency of the evidence is analyzed is whether the State presented competent, substantial evidence to support the verdict; (2) in this case, a rational trier of fact could have found the existence of the elements of the crime beyond a reasonable doubt; and (3) Defendant was not entitled to reversal of his convictions on any of his remaining allegations of error. View "Bush v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's successive motion to vacate his sentence of death under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in denying the Rule 3.851 motion.Appellant was convicted of first-degree murder, armed robbery, and grand theft. Appellant was sentenced to death for the murder. The Supreme Court affirmed the convictions but reversed Appellant's death sentence and remanded the case for a new penalty phase. After a new penalty phase, Appellant was again sentenced to death. In his successive Rule 3.851 motion, Appellant raised three claims. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court (1) properly denied Appellant's claim that his death sentence violated the Sixth and Eighth Amendments in light of Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016); (2) correctly denied Appellant's claim that his sentence violated the Eighth Amendment; and (3) did not err in denying Appellant's claim of newly discovered evidence. View "Archer v. State" on Justia Law

The Supreme Court affirmed Defendant's death sentences that were imposed after a second penalty phase, holding that there was no error or abuse of discretion.Defendant was convicted of two counts of first-degree murder and sentenced to death for each murder. The trial court granted a new penalty phase during postconviction proceedings on the grounds that counsel rendered ineffective assistance. After a second penalty phase, a death sentence was again imposed for each murder. The Supreme Court affirmed, holding (1) the trial court did not err by failing to instruct the jury that it must determine beyond a reasonable doubt whether the aggravators were sufficient to impose death and outweighed the mitigators; (2) none of the prosecutor's allegedly improper comments during closing argument rose to the level of fundamental error; (3) competent, substantial evidence supported the finding of the especially heinous, atrocious, or cruel aggravator; (4) the trial court did not abuse its discretion in rejecting two statutory mitigating circumstances presented with respect to both errors; and (5) the sentences of death were proportionate. View "Bright v. State" on Justia Law

The Supreme Court affirmed an order denying in part and dismissing in part Hector Sanchez-Torres's third amended motion filed under Fla. R. Crim. P. 3.851 to vacate judgments of conviction and sentence of death and denied Appellant's petition for habeas relief, holding that Sanchez-Torres was not entitled to relief on any of his claims.Sanchez-Torres pled guilty to armed robbery and first-degree murder. The trial court sentenced Sanchez-Torres to death. The Supreme Court affirmed. Sanchez-Torres then filed a motion to vacate his judgments of conviction and sentence. The postconviction court denied some of his claims and dismissed the others. Sanchez-Torres appealed and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court denied relief, holding (1) the postconviction court did not err in denying Sanchez-Torres's claims; and (2) Sanchez-Torres's claims of ineffective assistance of trial counsel and appellate counsel did not warrant habeas corpus relief. View "Sanchez-Torres v. State" on Justia Law

The Supreme Court approved the court of appeal's decision to uphold Defendant's sentence and disapproved of several recent court decisions to the extent they held that resentencing is required for all juvenile offenders serving a sentence longer than twenty years without the opportunity for early release based on demonstrated maturity and rehabilitation, holding that Defendant in this case did not establish a violation of Miller v. Alabama, 567 U.S. 460 (2012).Defendant was charged with the first-degree murder of her mother committed when she was age seventeen. Defendant pled guilty to second-degree murder in exchange for a forty-year sentence. Defendant later challenged her sentence as cruel and unusual punishment under Miller. The trial court denied Defendant's petition. The court of appeal affirmed but certified conflict with several decisions of other district courts. The Supreme Court affirmed, holding that because Defendant did not establish that her sentence was a life sentence or the functional equivalent of a life sentence Defendant failed to establish that her sentence violated the Eighth Amendment, Miller, or its equivalent on a juvenile homicide offender whose youth has not been taken into account at sentencing. View "Pedroza v. State" on Justia Law

The Supreme Court affirmed the order of the post conviction court denying Appellant's motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the postconviction court properly denied all claims argued in this appeal.In his postconviction motion Defendant raised several ineffective assistance of counsel claims, as well as a claim alleging retroactive application of Riley v. California, 573 U.S. 373 (2014). The postconviction court entered an amended order denying relief on all claims. The Supreme Court affirmed, holding (1) the alleged failures on the part of defense counsel did not rise to the level of ineffective assistance of counsel; and (2) Defendant's claim that he was entitled to a new trial under Riley was procedurally barred because Defendant failed to raise this claim on direct appeal. View "Smith v. State" on Justia Law

The Supreme Court affirmed the judgment of the post conviction court summarily denying Defendant's eighth successive motion to vacate his judgment of conviction and sentence, holding that all of Defendant's postconviction claims were legally insufficient or based on allegations that were conclusively refuted by the record.Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed. This case concerned Defendant's eighth successive motion to vacate the judgment of conviction and sentence. Along with his eighth successive motion Defendant filed a motion to compel discovery documents from the Office of the State Attorney. The postconviction court summarily denied Defendant's eighth successive postconviction motion and denied his motion to compel. The Supreme Court affirmed, holding (1) Defendant was not entitled to an evidentiary hearing on a newly discovered evidence claim alleging spoliation of evidence and a Brady violation; (2) Defendant was not entitled to an evidentiary hearing on his ineffective assistance of counsel claims; (3) the trial court did not err in summarily denying a standalone actual innocence claim; and (4) because Defendant failed to demonstrate his entitlement to the requested records the postconviction court correctly denied his motion to compel. View "Sweet v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying in part Marvin Cannon's initial postconviction motion filed pursuant to Fla. R. Crim. P. 3.851 and denied Cannon's petition for writ of habeas corpus, holding that Cannon was not entitled to relief on his claims.Cannon was convicted of first-degree murder and other crimes and sentenced to death. Cannon later filed his initial motion for postconviction relief, asserting that he was entitled to resentencing under Hurst v. State, 202 So. 3d 40 (Fla. 2016), that counsel was ineffective, and that the Department of Corrections' website reflected he was still serving a fifteen-year sentence for attempted robbery even though that conviction was vacated on direct appeal. The trial court agreed with Cannon's Hurst claim and vacated his death sentence but denied the remaining claims. The Supreme Court affirmed, holding that Cannon was not denied constitutionally effective assistance of counsel and that the postconviction court properly denied Cannon's second claim. In his habeas petition, Cannon alleged ineffective assistance of appellate counsel. The Supreme Court denied the petition, holding that appellate counsel was not ineffective for failing to raise a procedurally barred claim. View "Cannon v. State" on Justia Law

The Supreme Court quashed the decision of the First District Court of Appeal vacating Defendant's sentence and remanding for resentencing under the prior version of Fla. Stat. 775.082(1), which could have resulted in reimposition of Defendant's sentence without any findings by a jury or the trial court, holding that the proper remedy for harmful error resulting from the court, not the jury finding the fact of dangerousness under section 775.082(1) is to remand for resentencing.In Brown v. State, 260 So. 3d 147, 150 (Fla. 2018), the Supreme Court held that the portion of section 775.082(10) requiring the court, not the jury, to find the fact of dangerousness to the public necessary to increase the statutory maximum nonstate prison sanction violated the Sixth Amendment. At issue in this case was the proper remedy for harmful error resulting from the court finding the fact of dangerousness under the statute. The First District held that statutory revival was the proper remedy. The Supreme Court quashed the First District's decision, holding that the proper remedy is to remand for resentencing with instructions to either impose a nonstate sanction of up to one year in county jail or empanel a jury to make the determination of dangerousness, if the State so requests. View "Gaymon v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the trial court's judgment ordering a new penalty phase proceeding after finding Defendant was entitled to relief under Hurst v. State, 202 So. 3d 40 (Fla. 2016), and rejecting Defendant's guilt-phase claim, holding that this Court must partially recede from Hurst.The jury in Defendant's case recommended death by a vote of eleven to one after unanimously finding that, during the course of the first-degree murder, Defendant committed related crimes. Defendant later filed his postconviction motion alleging that counsel was ineffective for conceding that Defendant committed the nonhomicide offenses for which he was convicted and that Defendant was entitled to resentencing because the jury did not make the findings required by Hurst. The trial court denied Defendant's ineffective assistance of counsel claim but vacated Defendant's death sentence pursuant to Hurst. The Supreme Court reversed in part, holding (1) this Court recedes from Hurst except to the extent it requires a jury unanimously to find the existence of a statutory aggravating circumstance; and (2) under a correct understanding of Hurst v. Florida, 136 S. Ct. 616 (2016), the requirement that a jury unanimously find a statutory aggravating circumstance beyond a reasonable doubt was satisfied in this case. View "State v. Poole" on Justia Law