Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the order of the circuit court denying Appellant’s motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding, among other things, that Appellant’s attorney was not ineffective for failing to investigate and present certain mitigation evidence.Appellant was convicted of kidnapping and first-degree murder and sentence of death. In her motion for postconviction relief Appellant raised fourteen initial claims and then amended her motion to add a Hurst claim. The trial court denied the motion in its entirety. The Supreme Court affirmed, holding that trial counsel’s performance was not deficient, the State did not commit a Giglio violation, and Appellant was not entitled to a new penalty phase under Hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State, 202 So. 3d 40 (Fla. 2016). View "Allen v. State" on Justia Law

The Supreme court affirmed the circuit court’s order granting in part and denying in part Appellant’s motion for DNA testing under Fla. R. Crim. P. 3.853, holding that none of Appellant’s claims on appeal had merit.After a retrial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed on direct appeal. Appellant later filed his motion for DNA testing of evidence pursuant to Rule 3.853. After an evidentiary hearing, the circuit court granted the motion in part and denied it in part. Appellant appealed the circuit court’s partial denial of his Rule 3.853 motion. The Supreme Court affirmed, holding (1) the circuit court did not err in adopting the State’s reasoning and conclusions as to Appellant’s motion in its order; and (2) the partial denial of Appellant’s motion did not violate his Fifth, Eighth, or Fourteenth Amendment rights. View "Gosciminski v. State" on Justia Law

The Supreme Court quashed the decision of the First District Court of Appeal holding that it was appropriate for an appellate court to review the entire evidentiary record to determine whether multiple convictions violate double jeopardy, holding that, consistent with State v. Shelley, 176 So. 3d 914 (Fla. 2015), to determine whether multiple convictions of solicitation of a minor, unlawful use of a two-way communications device, and traveling after solicitation of a minor are based upon the same conduct for purposes of double jeopardy, the reviewing court should consider only the charging document.Defendant moved to dismiss the charges against him, arguing that they violated double jeopardy because the elements of solicitation of a minor and unlawful use of a two-way communications device were subsumed within the elements of traveling after solicitation. The trial court denied the motion, and Defendant was convicted of all three counts. The First District affirmed after examining the entire record, concluding that there was no double jeopardy violation. The Supreme Court reversed, holding that the reviewing court should have considered only the charging document in determining whether Defendant’s convictions were based upon the same conduct for purposes of double jeopardy. View "Lee v. State" on Justia Law

The Supreme Court quashed the decision of the Fourth District Court of Appeal affirming the denial of Defendant’s motion to suppress and remanded this case to the district court with instructions that the case be remanded for a new trial without introducing portions of statements made after Defendant unequivocally invoked his right to silence, holding that the statements were produced as a result of a Miranda violation, and the error was not harmless.Defendant, who was convicted of first-degree murder and attempted first-degree murder, appealed the denial of his motion to suppress his confession on the basis that detectives had violated his right against self-incrimination and right to counsel. The Fourth District affirmed. The Supreme Court quashed the Fourth District’s decision, holding (1) a detective’s statements after Defendant unequivocally invoked his right to silence constituted interrogation; (2) the State was unable to meet its burden of demonstrating that Defendant’s subsequent Miranda waiver was voluntarily made; and (3) therefore, the trial court erred in admitting Defendant’s confession. View "Shelly v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant’s successive motion for postconviction relief under Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief pursuant to Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), nor was he entitled to relief on his other claims.Appellant was convicted of the 1992 first-degree murder of his wife. The jury recommended a death sentence by a vote of seven to five. The trial court imposed a sentence of death. Appellant later filed a successive motion to vacate his death sentence in light of Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst. The circuit court summarily denied the motion. The Supreme Court affirmed, holding that because Appellant’s sentence became final prior to Ring v. Arizona, 536 U.S. 584 (2002), Appellant was not entitled to Hurst relief. View "Spencer v. State" on Justia Law

The Supreme Court approved the decision of the First District Court of Appeal affirming the trial court’s denial of Defendant’s motion to vacate his 1000-year sentences with parole eligibility pursuant to Fla. R. Crim. P. 3.850, holding that Defendant’s sentences did not violate the categorical rule of Graham v. Florida, 560 U.S. 48 (2010).Defendant committed nonhomicide crimes at age seventeen and received concurrent sentences of 1000 years. The Parole Commission, after eleven review hearings, calculated a presumptive parole release date of 2352. After the United States Supreme Court decided Graham and Miller v. Alabama, 567 U.S. 460 (2012), Defendant filed a motion to vacate his sentences pursuant to Fla. R. Crim. P. 3.850, arguing that his sentences violated the Eighth Amendment as delineated in Graham. The trial court denied the motion, and the First District Court of Appeal affirmed. The Supreme Court affirmed, holding that Defendant was not entitled to resentencing under chapter 2014,200, Laws of Florida. View "Franklin v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s orders summarily denying Appellant’s fifth and sixth successive motions for postconviction relief filed under Fla. R. Crim. P. 3.851, the postconviction court's order denying Appellant’s motion to amend his sixth successive postconviction motion, and the postconviction court's order denying Appellant’s motion to correct illegal sentence filed under Fla. R. Crim. P. 3.800(a), holding that Appellant was not entitled to relief on his claims.Appellant was found guilty of first-degree murder and sentenced to death. Pending before the Supreme Court were Appellant’s challenges to the summary denials of his fifth and sixth successive postcondition motions and the denials of his motion to correct illegal sentence and motion to amend. The Supreme Court affirmed the postconviction court’s orders, holding that Appellant’s arguments on appeal were unavailing. View "Jimenez v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s order denying Appellant’s successive motion for postconviction relief, holding that Appellant was not entitled to relief on his claims.Appellant was convicted of first-degree murder and sentenced to death following a jury’s recommendation for death by a vote of eleven to one. The death sentence became final in 1988. Appellant later filed a motion pursuant to Fla. R. Crim. P. 3.851 seeking relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). The motion was denied. The Supreme Court affirmed, holding (1) Hurst did not apply retroactively to Appellant’s sentence of death; and (2) Appellant was not denied due process by the substitution of judges on his case between the denial of his motion for postconviction relief and his motion for rehearing. View "Jennings v. State" on Justia Law

The circuit court denied Zakrzewski’s motion under Florida Rule of Criminal Procedure 3.851, seeking relief pursuant to the U.S. Supreme Court’s 2016 decision in Hurst v. Florida. The Supreme Court of Florida affirmed the denial of relief, concluding that its prior denial of Zakrzewski’s petition for a writ of habeas corpus raising similar claims is a procedural bar to the claims at issue. All of Zakrzewski’s claims depend upon the retroactive application of Hurst, to which the court has held he is not entitled. View "Zakrzewski v. Florida" on Justia Law

Lynch pled guilty to two counts of first-degree premeditated murder, one count of armed burglary of a dwelling, and one count of kidnapping, all stemming from the 1999 deaths of Morgan and her 13-year-old daughter. Lynch’s counsel recommended that he waive a penalty phase jury because a jury would be more emotional and unsympathetic to mitigation presented for the murder of a child than a seasoned trial judge. Lynch waived his right to a penalty phase jury. The court sentenced Lynch to death. The Supreme Court of Florida affirmed. In 2003, the U.S. Supreme Court denied Lynch’s petition for certiorari. The Supreme Court of Florida affirmed the denial of Lynch’s initial motion for postconviction relief and denied his petition for habeas corpus. The Eleventh Circuit affirmed the denial of Lynch’s petition for federal habeas relief and, in 2016, the Supreme Court denied Lynch’s petition for certiorari to the Eleventh Circuit. Lynch filed a successive motion for postconviction relief, citing Hurst v. State. The Supreme Court of Florida affirmed the denial of relief. Lynch is not entitled to Hurst relief in light of his valid waiver of a penalty phase jury. Lynch argued, that the test for prejudice under the Strickland standard for ineffective assistance has changed post-Hurst. The court stated that trial counsel is not required to anticipate changes in the law in order to provide effective legal representation. View "Lynch v. Florida" on Justia Law