Justia Criminal Law Opinion Summaries

A defendant was convicted of first-degree felony murder, aggravated child abuse, and sexual battery following the 1992 death of a two-year-old child. The evidence at trial showed that the defendant was alone with the victim, who was later found unconscious, with visible injuries and blood present in the apartment and on the defendant’s clothing. The medical examiner concluded the cause of death was a cerebral hemorrhage from multiple blows to the head. The defendant claimed the child’s injuries were accidental or caused by another individual, but the jury rejected this defense and recommended a death sentence, which was imposed.After the conviction and sentence were affirmed by the Supreme Court of Florida, the defendant filed several postconviction motions and habeas petitions, all of which were denied. In the most recent proceedings, the defendant filed a fourth successive motion for postconviction relief in the Circuit Court for Duval County. The motion argued that microscopic slides from the autopsy constituted newly discovered evidence and that the State had suppressed exculpatory information in violation of Brady v. Maryland. The circuit court summarily denied the motion, finding the claims untimely and without merit, noting that the existence of the slides and the finding of pneumonia were disclosed in the original autopsy report and available to the defense.On appeal, the Supreme Court of Florida reviewed the summary denial de novo. The court held that both the Brady and newly discovered evidence claims were untimely because the defendant knew or could have known of the evidence with due diligence. The court further held that no evidence was suppressed and that the new expert’s conclusions did not meet the standards for materiality or probability of acquittal required for relief. The court affirmed the summary denial of postconviction relief. View "Davis v. State of Florida" on Justia Law

An individual was convicted of the 2010 first-degree felony murder of an elderly woman, Janet Patrick, after being seen with her at a grocery store and later found in possession of her car and credit cards. The victim’s body was discovered in a wooded area, and forensic evidence linked the defendant to the crime scene and the victim’s vehicle. The defendant was also charged with robbery and kidnapping. His defense at trial was based on claims of mental illness or seizures. The jury found him guilty on all counts.The Florida Supreme Court previously affirmed the convictions and non-capital sentences but reversed the death sentence because the jury’s recommendation was not unanimous, as required by Hurst v. State. After subsequent legal developments, including State v. Poole and State v. Okafor, the defendant was granted a new penalty phase. During the new penalty phase, the defendant represented himself, waived a jury trial, and declined to present mitigation evidence. The trial court denied his motion for a continuance to secure a new mitigation specialist, finding that he had been given multiple opportunities to obtain such assistance. The court ultimately sentenced him to death, finding four aggravating factors and several mitigating circumstances.On direct appeal, the Supreme Court of Florida reviewed four claims: denial of the motion to continue, voluntariness of waivers of jury and mitigation, access to discovery, and the constitutionality of Florida’s death penalty scheme. The court held that the trial court did not abuse its discretion in denying the continuance, that the waivers were knowing and voluntary, that discovery obligations were met, and that the capital sentencing scheme was constitutional. The court affirmed the sentence of death. View "Williams v. State of Florida" on Justia Law

In 2009, Timothy W. Fletcher was convicted of first-degree murder for the death of Helen Googe. Fletcher and his cellmate, Doni Ray Brown, escaped from jail and went to Googe’s home to steal money. Fletcher confessed to his involvement, although he initially claimed Brown was the primary aggressor. The physical evidence, including DNA under Googe’s fingernails, linked Fletcher to the crime. The jury found Fletcher guilty and recommended the death penalty by a vote of eight to four.Fletcher’s initial death sentence was vacated due to a non-unanimous jury recommendation, and he was granted a new penalty phase under Hurst v. State. During the new penalty phase, the State presented evidence to support four aggravating factors, while Fletcher presented evidence of forty-nine mitigating circumstances. The jury unanimously found all four aggravating factors and recommended the death penalty. The trial court merged two aggravators and found three aggravating factors, giving them great weight, and considered fifty-two mitigating factors, giving moderate weight to the cumulative mitigation.Fletcher appealed to the Supreme Court of Florida, raising nine issues, including claims of prosecutorial misconduct, jury nullification, and the constitutionality of Florida’s capital sentencing scheme. The court found no reversible error, concluding that the prosecutor’s comments did not improperly denigrate mitigating evidence, the jury followed instructions, and the victim impact evidence was admissible. The court also rejected Fletcher’s constitutional challenges to the death penalty statute and the aggravating factors applied in his case. The court affirmed Fletcher’s death sentence, finding that the trial court properly weighed the aggravating and mitigating factors and that the jury’s recommendation was supported by the evidence. View "Fletcher v. State of Florida" on Justia Law

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