Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the order of the circuit court denying Appellant's third amended motion to vacate his conviction of first-degree murder and sentence of death filed pursuant to Fla. R. Crim. P. 3.851 and denied Appellant's petition for a writ of habeas corpus, holding that Appellant was not entitled to relief.Appellant was convicted of first-degree murder and sentenced to death. This appeal concerned Appellant's second amended motion for postconviction relief. The postconviction court noted that Appellant was entitled to a new penalty phase pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016) but denied the guilt-phase claims. The majority of the claims presented in Appellant's appeal alleged ineffective assistance of trial counsel. The Supreme Court denied the claims and affirmed the order of the postconviction court. The Court also denied Appellant's petition for writ of habeas corpus, holding that Appellant's claim that comments made by the prosecutor tapped into racial stereotypes was procedurally barred and that Appellant's claim of ineffective assistance of appellate counsel also failed. View "Martin v. State" on Justia Law

The Supreme Court affirmed the denial of Sparre's postconviction motion to vacate his conviction of first-degree murder and sentence of death filed under Fla. R. Crim. P. 3.851 and denied his petition for writ of habeas corpus, holding that Sparre was not entitled to relief.As to Sparre's appeal from the denial of his postconviction motion, the Supreme Court held (1) trial counsel was not ineffective, despite two instances in which counsel was deficient; (2) the trial court properly denied Sparre's claim that the cumulative effect of trial counsel's errors entitled him to relief; and (3) Sparre's claims that the postconviction court erred in three other respects were without merit. As to Sparre's habeas petition, the Court held that Sparre was not entitled to relief on his claims of ineffective assistance of appellate counsel. View "Sparre v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying Defendant relief from his conviction and denied Defendant's habeas conviction, holding that Defendant was not entitled to relief.Defendant was found guilty of first-degree felony murder and robbery with a firearm or other deadly weapon. Defendant later moved for postconviction relief. The trial court vacated Defendant's death sentence and ordered a new penalty phase pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016). Defendant appealed the denial of his guilt phase claims and petitioned the Supreme Court for a writ of habeas corpus. In the appeal from the postconviction motion, the Supreme Court affirmed, holding that Defendant was not entitled to relief on his allegations of error. The Court then denied habeas relief, holding that appellate counsel was not ineffective on direct appeal. View "Jordan v. State" on Justia Law

The Supreme Court declined to answer a question certified by the Fourth District Court of Appeal regarding whether, under the Fourth Amendment, a warrantless blood draw of an unconscious person incapable of giving consent may be pursuant to Fla. Stat. 316.1932(1)(c) so that the unconscious person can be said to have "consented" to the blood draw, holding that this case fell squarely within the rule announced in Mitchell v. Wisconsin, 139 S. Ct. 2525 (2019).The Wisconsin Supreme Court analyzed the Fourth Amendment issue using the "consent" framework of the statute. During the pendency of this appeal the United States Supreme Court considered a materially indistinguishable issue relating to a similar Wisconsin statute and vacated the Wisconsin Supreme Court's decision. The Supreme Court declined to address the certified question as framed, applied Mitchell, vacated the Fourth District's decision, and remanded, holding that because this case fell within the rule announced in Mitchell, the warrantless blood draw was legal. View "McGraw v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying John Mack Sketo Calhoun's motion to vacate his conviction of first-degree murder filed under Fla. R. Crim. P. 3.851 and denied Calhoun's petition for a writ of habeas corpus, holding that Calhoun was not entitled to relief.Specifically, the Supreme Court held (1) as to Calhoun's postconviction appeal, the circuit court properly denied relief as to Calhoun's newly discovered evidence claim, trial counsel was not ineffective during the guilt phase, and none of Calhoun's remaining claims warranted relief; and (2) as to Calhoun's habeas petition, Calhoun failed to demonstrate that appellate counsel was ineffective on direct appeal. View "Calhoun v. State" on Justia Law

The Supreme Court affirmed the circuit court's summary denial of Appellant's second successive motion for postconviction relief, holding that the petition was both untimely and procedurally barred.Appellant was convicted of first-degree murder and sentenced to death. Several years later, Appellant filed his second successive motion for postconviction relief under Fla. R. Crim. P. 3.851, arguing that, in Buck v. Davis, 137 S. Ct. 759 (2017), the United States Supreme Court established a new fundamental constitutional right that the injection of racial bias and prejudice into a criminal trial constitutes per se ineffective assistance of counsel. Further, Appellant argued that this right applies to convictions and sentences, like his, that became final before Buck. The Supreme Court disagreed, holding (1) Appellant's motion was untimely because Buck did not establish a new right; and (2) because this Court previously addressed the arguments at issue and held that they did not warrant relief Appellant's motion was procedurally barred. View "Bell v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction and death sentence for first-degree murder, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Court held (1) the jury instructions during the penalty phase were sufficient; (2) the trial court did not err in admitting Defendant's letters to a predecessor judge and the elected state attorney; (3) the trial court's findings of the CCP aggravator were supported by competent, substantial evidence; (4) there was no error in the court's analysis of the prior violent felony aggravator; (5) the sentencing order was sufficient; (6) the evidence was sufficient to sustain the murder conviction; and (7) the death sentence was proportionate. View "Rogers v. State" on Justia Law

The Supreme Court affirmed the postconviction court's order denying Appellant's third successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the postconviction court did not err in denying relief.Appellant pleaded guilty to first-degree murder, kidnapping, and sexual battery and was sentenced to death. Appellant filed his current challenge to his death sentence - his third successive under Rule 3.851 - after the governor signed his death warrant. The postconviction court denied his motion. The Supreme Court affirmed, holding that the postconviction court did not err in (1) summarily denying Appellant's newly discovered evidence claim; (2) denying Appellant's challenges to Florida's lethal injection protocol; (3) summarily denying Appellant's claim that adding his execution to the more than thirty years he has spent on death row constitutes cruel and unusual punishment; and (4) denying the remainder of Appellant's claims. View "Long v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions of first-degree murder and six sentences of death, holding that no reversible error occurred in the proceedings below and that each of the death sentences was appropriate.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion when it declined Defendant’s request for self-representation; (2) there was no improper doubling of aggravators; (3) Defendant’s challenge to the constitutionality of the death penalty was procedurally barred; (4) Defendant’s guilty pleas were knowing, intelligent, and voluntary; and (5) each of Defendant’s death sentences was proportionate. View "Damas v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Appellant’s motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Hurst v. State, 202 So. 3d 40 (Fla. 2016), did not apply retroactively to Appellant’s sentence of death.Appellant was convicted of first-degree murder and sentenced to death. The jury recommended death by a vote of seven to five. Appellant’s death sentence became final in 1993. In his postconviction motion, Appellant sought relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst. The Supreme Court affirmed the postconviction court’s order denying relief, holding that Appellant was not entitled to relief under Hurst. View "Thompson v. State" on Justia Law