Justia Criminal Law Opinion Summaries

A woman’s nude body was discovered near the Vaca Cut Bridge in Marathon, Florida, with evidence of ligature strangulation and severe sexual injuries. Car parts found near the body matched damage to a conversion van driven by Steven Wolf, who was detained nearby. Wolf gave inconsistent statements to law enforcement, initially denying involvement but later admitting to being present when the victim died in his van and to disposing of evidence. Forensic evidence, including DNA, linked Wolf to the victim and the crime scene. The medical examiner determined the victim was alive during the infliction of fatal injuries, which could not have been caused by male genitalia, and that she suffered extreme pain before death.Wolf was charged in the Circuit Court with first-degree murder, two counts of sexual battery with force likely to cause injury, and tampering with physical evidence. He was found guilty on all counts by a jury. During the penalty phase, the State presented evidence of Wolf’s prior violent felony conviction. The jury unanimously found all aggravating factors proven and recommended a death sentence. The trial court agreed, finding the aggravating factors outweighed the mitigating circumstances and sentenced Wolf to death.On direct appeal, the Supreme Court of Florida reviewed Wolf’s claims, including challenges to venue, jury selection, evidentiary rulings, prosecutorial misconduct, jury instructions, and the sufficiency of the evidence. The court held that venue was properly established in Monroe County, the trial court did not abuse its discretion in jury selection or evidentiary rulings, and the improper prosecutorial comments did not rise to fundamental error. The court also found sufficient evidence supported the convictions and the especially heinous, atrocious, or cruel aggravator. The Supreme Court of Florida affirmed Wolf’s convictions and sentence of death. View "Wolf v. State of Florida" on Justia Law

The appellant was married to the victim, with whom he shared two daughters, and was also living with her two sons from a previous marriage. In July 2019, following an argument, he killed his wife by beating her with a baseball bat and concealed her body in their home. Over the following weeks, he lied to family and friends about her whereabouts, impersonating her in communications. As the children returned home before the start of school, he became concerned that the boys might reveal their mother’s absence. He then killed the two boys, one by strangulation and the other by drowning, and later killed his two daughters in a similar manner. He concealed all five bodies in storage boxes, eventually transporting them in a minivan. After a wellness check was requested by the victim’s family, law enforcement began investigating. The appellant fled the state, ultimately confessing to the murders after a car accident in Georgia, and led police to the children’s remains.A grand jury in Marion County, Florida, indicted the appellant on four counts of first-degree murder (for the children) and one count of second-degree murder (for his wife). He pleaded guilty to all charges. At the penalty phase, the State sought six aggravating factors for each first-degree murder count. The defense presented expert testimony regarding the appellant’s mental health, arguing for mitigation. The trial court denied a defense request for a special jury instruction on the “avoid arrest” aggravator, gave the standard instruction, and the jury recommended death sentences. The court imposed four death sentences, finding all aggravators proven and that they outweighed mitigation.The Supreme Court of Florida reviewed the case, affirming the convictions and sentences. The court held that the trial court did not abuse its discretion in denying the special jury instruction, found Florida’s capital sentencing scheme constitutional, and determined the appellant’s guilty plea was knowingly, intelligently, and voluntarily entered. The convictions and death sentences were affirmed. View "Jones v. State of Florida" on Justia Law

Michael Bernard Bell was convicted of the 1993 first-degree murders of Jimmy West and Tamecka Smith. Bell sought revenge for his brother's death and purchased an AK-47. He mistakenly identified West as his target and shot both West and Smith. Bell was sentenced to death, with the trial court finding three aggravating factors and one mitigating circumstance. The Florida Supreme Court affirmed his convictions and sentences on direct appeal, and the U.S. Supreme Court denied certiorari.Bell filed multiple postconviction relief motions. The circuit court denied his initial motion, but the Florida Supreme Court remanded for an evidentiary hearing, which ultimately resulted in a denial of relief. Subsequent motions were also denied, including claims related to retroactive application of legal decisions and ineffective assistance of counsel. Bell's federal habeas petitions were similarly unsuccessful.Governor Ron DeSantis signed Bell’s death warrant in June 2025, prompting Bell to file a successive motion for postconviction relief, raising claims of newly discovered evidence, Brady and Giglio violations, and racial bias. The circuit court granted an evidentiary hearing on the newly discovered evidence claim but ultimately denied relief.The Florida Supreme Court reviewed the case and affirmed the circuit court's denial of Bell’s successive postconviction motion. The court found that Bell's claims of newly discovered evidence, including alleged recantations and prosecutorial misconduct, were either untimely or lacked merit. The court also rejected Bell's arguments regarding the totality of circumstances and the timeframe of his death warrant. Consequently, the court denied Bell's motion for a stay of execution and his request for oral argument. View "Bell v. State of Florida" on Justia Law

Scottie D. Allen, a prisoner under a death sentence, appealed the circuit court's summary denial of his initial motion for postconviction relief under Florida Rule of Criminal Procedure 3.851 and the denial of his request for public records under Rule 3.852. Allen also petitioned for a writ of habeas corpus. Allen was convicted of first-degree premeditated murder for strangling his cellmate, Ryan Mason, at Wakulla Correctional Institution. Allen represented himself during the trial and penalty phases, where he confessed to the murder and declined to present any mitigation.The trial court found Allen competent to waive counsel and represent himself. The jury convicted Allen and recommended the death penalty, finding four aggravating factors. The trial court ordered a presentence investigation report (PSI) and appointed amicus counsel to present mitigation at the Spencer hearing. Despite Allen's objections, the trial court allowed the State's mental health expert to evaluate him. The trial court sentenced Allen to death, finding significant aggravating factors and some mitigating circumstances.On direct appeal, the Florida Supreme Court affirmed Allen's conviction and death sentence. Allen then filed a motion for postconviction relief, raising several claims, including issues with the PSI, the trial court's handling of mitigation, and his competency to represent himself. The circuit court summarily denied the motion, finding the claims procedurally barred or without merit.The Florida Supreme Court reviewed the case and affirmed the circuit court's denial of postconviction relief and the request for additional public records. The court found that Allen's claims were procedurally barred as they could have been raised on direct appeal and were without merit. The court also denied Allen's habeas petition, concluding that his appellate counsel was not ineffective for failing to raise meritless or unpreserved issues. View "Allen v. State of Florida" on Justia Law

The case involves Jourdan Parks, who was adjudicated guilty of five charges and sentenced to 25 years in prison as a habitual felony offender. The trial court also imposed a $100 cost for the state attorney as mandated by section 938.27(8) of the Florida Statutes, despite the State not expressly requesting it. Parks moved to correct this alleged sentencing error, arguing that subsection (1) of the same statute required a request by the State for such costs. The trial court rejected this argument, relying on the 2008 amendment to subsection (8) that mandates these costs.The First District Court of Appeal affirmed the trial court's decision, holding that the minimum cost for the state attorney is mandatory under subsection (8) and does not require a request by the State. This decision conflicted with the Second District Court of Appeal's ruling in D.L.J. v. State, which held that a request by the State was necessary for imposing such costs, based on subsection (1) of the statute.The Supreme Court of Florida reviewed the case to resolve the conflict between the First and Second District Courts of Appeal. The Court concluded that the specific mandate of subsection (8), which requires the imposition of minimum costs for the state attorney without a request by the State, controls over the general language of subsection (1). The Court approved the First District's decision in Parks and disapproved the Second District's decision in D.L.J., holding that the minimum costs for the state attorney must be imposed even in the absence of a request by the State. View "Parks v. State of Florida" on Justia Law

In August 2020, Sarah Baker discovered her two sons, Robert and Tayten, brutally murdered in their home. Mark Wilson, the boyfriend of Sarah’s sister, had recently moved into a shed on the Bakers’ property. Evidence, including a hammer and fillet knife with blood, and a note from Wilson, linked him to the crime. Wilson confessed to his mother and law enforcement, detailing the murders and claiming he believed the boys were abusing his daughter. He was charged with first-degree murder, burglary with assault or battery, and burglary of a dwelling while armed.The trial court found Wilson guilty on all counts. During the penalty phase, the jury unanimously found several aggravating factors, including that the murders were committed in a cold, calculated, and premeditated manner (CCP). The trial court agreed with the jury’s findings and sentenced Wilson to death for each murder and a consecutive life sentence for burglary while armed.The Supreme Court of Florida reviewed the case and affirmed the convictions and sentences. The court held that there was credible and competent evidence to support the CCP aggravator, including Wilson’s premeditation and lack of provocation from the victims. The court also found no error in the trial court’s rejection of Wilson’s claim of methamphetamine intoxication at the time of the murders, since there was insufficient evidence to support it. Additionally, the court upheld the admission of victim impact evidence, the denial of a special jury instruction regarding a life sentence, and the use of the word “reasonably” in the jury instructions. The court also rejected Wilson’s arguments against the death penalty and found the evidence sufficient to support the convictions. View "Wilson v. State" on Justia Law

In 1995, Glen Edward Rogers murdered Tina Marie Cribbs in Hillsborough County, Florida. Rogers was convicted of first-degree murder, armed robbery, and grand theft of a motor vehicle. He was sentenced to death, and his conviction and sentence were affirmed on direct appeal. Rogers has since filed multiple postconviction motions, all of which have been denied.Rogers' fourth successive postconviction motion raised three claims: (1) he was unconstitutionally deprived of the right to challenge his conviction and sentence due to a conflict of interest with his counsel, (2) newly discovered evidence of his childhood sexual abuse and trafficking would result in a life sentence on remand, and (3) Florida’s lethal injection procedures are cruel and unusual due to his porphyria diagnosis. The postconviction court summarily denied these claims as untimely, procedurally barred, and/or meritless.The Supreme Court of Florida reviewed the case and affirmed the postconviction court's denial. The court found that Rogers' conflict-of-counsel claim was procedurally barred and without merit, as there was no actual conflict of interest. The newly discovered evidence claim was also found to be procedurally barred and meritless, as the evidence could have been discovered with due diligence. Lastly, the court held that Rogers' method-of-execution claim was untimely and meritless, as he failed to demonstrate that Florida’s lethal injection protocol would cause him substantial and imminent risk of serious illness and needless suffering, and he did not identify a viable alternative method of execution.The Supreme Court of Florida denied Rogers' motion for a stay of execution and his request for oral argument, affirming the summary denial of his fourth successive postconviction motion. View "Rogers v. State" on Justia Law

Jeffrey G. Hutchinson was convicted of murdering his girlfriend Renee Flaherty and her three children in 1998. After an argument with Renee, Hutchinson drank heavily, returned to her home with a shotgun, and killed Renee and two of her children with single shots to the head. He then shot the third child, Geoffrey, twice, killing him. Hutchinson called 911, admitting to the shootings, and was found by police with gunshot residue on his hands and body tissue from Geoffrey on his leg. He was charged with four counts of first-degree murder and sentenced to death for the murders of the three children.Hutchinson's convictions and death sentences were affirmed on direct appeal by the Florida Supreme Court. He filed multiple postconviction motions, all of which were denied. His initial state postconviction motion and successive motions were also denied, as were his federal habeas petitions. His fourth successive postconviction motion, filed after the Governor signed a death warrant, was denied by the circuit court without an evidentiary hearing.The Supreme Court of Florida reviewed Hutchinson's appeal of the denial of his fourth successive postconviction motion and his habeas corpus petition. The court affirmed the circuit court's denial, rejecting Hutchinson's claims that the warrant period violated his constitutional rights, that the warrant selection process was arbitrary, and that his execution would be cruel and unusual punishment. The court also denied his habeas claims, including his argument that Atkins v. Virginia should extend to individuals with neurocognitive disorders and his challenge to the heinous, atrocious, or cruel (HAC) aggravator. The court denied Hutchinson's requests for a stay and oral argument, and ordered the mandate to issue immediately. View "Hutchinson v. State" on Justia Law

Michael A. Tanzi was sentenced to death for the murder of Janet Acosta. On March 10, 2025, Governor Ron DeSantis signed a death warrant scheduling Tanzi’s execution for April 8, 2025. Tanzi sought relief in the circuit court, which was denied, leading to his appeal to the Supreme Court of Florida.The circuit court had previously denied Tanzi’s first motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, and the Florida Supreme Court affirmed this denial. Tanzi’s petition for state habeas relief was also denied. He then sought federal habeas relief, which was denied by the district court and affirmed by the Eleventh Circuit. Tanzi’s subsequent motion for postconviction relief under Hurst v. Florida was denied by the Florida Supreme Court, which found the Hurst error in his case harmless beyond a reasonable doubt.The Supreme Court of Florida reviewed Tanzi’s appeal of the denial of his third motion for postconviction relief, which raised claims about due process violations due to the compressed warrant period, the constitutionality of Florida’s lethal injection protocols, and the Governor’s authority in determining the timing of death warrants. The court affirmed the circuit court’s summary denial of these claims, finding them either procedurally barred or without merit. The court also denied Tanzi’s habeas petition, which argued that his death sentence was unconstitutional under Erlinger v. United States, and dismissed his emergency petition to invoke the court’s all writs jurisdiction.The Supreme Court of Florida held that the warrant litigation schedule did not violate Tanzi’s due process rights, the denial of public records requests was not an abuse of discretion, and the lethal injection protocol did not constitute cruel and unusual punishment. The court also upheld the Governor’s authority in signing death warrants and found no merit in Tanzi’s habeas petition. The court denied all of Tanzi’s motions and requests, including a stay of execution. View "Tanzi v. State" on Justia Law

James D. Ford was convicted of the 1997 murders of Greg and Kimberly Malnory at a sod farm in South Florida. Ford, who worked with Greg, had planned to go fishing with the couple. Greg was shot in the head, beaten, and had his throat slit. Kimberly was raped, beaten, and shot. Their young daughter was found nearby, unharmed but exposed to the elements. Ford was convicted of two counts of first-degree murder, sexual battery with a firearm, and child abuse, and was sentenced to death.Ford's convictions and sentences were affirmed on direct appeal, and the U.S. Supreme Court denied certiorari in 2002. Ford has since filed multiple unsuccessful postconviction relief motions in state and federal courts. His third successive motion for postconviction relief, filed under Florida Rule of Criminal Procedure 3.851, was summarily denied by the circuit court. This motion raised claims that his death sentence was unconstitutional under Roper v. Simmons due to his mental and developmental age and that executing him would violate his rights under the Fifth, Sixth, Eighth, and Fourteenth Amendments in light of Erlinger v. United States.The Supreme Court of Florida reviewed the case and affirmed the circuit court's denial. The court held that Ford's claim regarding his mental and developmental age was untimely and without merit, as Roper does not extend to individuals over eighteen, regardless of mental age. The court also found that Erlinger, which involved the federal Armed Career Criminal Act, was not applicable to Ford's case. Additionally, the court rejected Ford's arguments related to Hurst v. Florida and Hurst v. State, noting that these decisions do not apply retroactively to Ford's case. The court concluded that Ford's claims were procedurally barred and meritless, and affirmed the denial of his third successive motion for postconviction relief. View "Ford v. State" on Justia Law