Justia Criminal Law Opinion Summaries

Articles Posted in Florida Supreme Court
by
The Supreme Court affirmed the order of the circuit court dismissing in part and denying in part James Dailey's third successive motion for postconviction relief and also denied Dailey's motion for stay of execution and his petition for a writ of habeas corpus, holding that Dailey was not entitled to relief on any of his claims. Dailey was convicted of first-degree murder and sentenced to death. After his death warrant was signed, Dailey filed his third successive motino for postconviction relief, which the circuit court dismissed in part and denied in part. The Supreme Court affirmed the postconviction court's denial of relief and denied Dailey's habeas petition, holding (1) the circuit court properly rejected Dailey's claims that his execution would be unconstitutionally arbitrary; (2) the circuit court did not err in rejecting Dailey's claim that newly discovered evidence proved the State committed Brady and Giglio violations; (3) the circuit court did not err in denying Dailey's requests for certain public records; and (4) Dailey was procedurally barred from raising his claims in his habeas petition. View "Dailey v. State" on Justia Law

by
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

by
The Supreme Court affirmed the order of the circuit court summarily denying Appellant's successive motion for postconviction relief, holding that the circuit court properly denied relief. Appellant pleaded guilty to first-degree murder, sexual battery, and other crimes. The trial judge sentenced Appellant to death for the murder. The Supreme Court affirmed the convictions and sentences on direct appeal. Appellant later filed a successive postconviction motion under Fla. R. Crim. P. 3.851, arguing that his death sentence was unconstitutional under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 S. 3d 40 (Fla. 2016). The circuit court summarily denied the motion. The Supreme Court affirmed, holding that Appellant's claim was procedurally barred to the extent it was raised in his earlier postconviction appeal and, additionally, failed on the merits. View "Brant v. State" on Justia Law

by
The Supreme Court denied Petitioner's petition to invoke this Court's discretionary jurisdiction, holding that the Florida Constitution does not authorize the Supreme Court to review cases that "may present federal issues." Petitioner, an inmate, filed a motion for postconviction relief alleging ineffective assistance of counsel. The postconviction court denied the motion, ruling that Petitioner had failed to demonstrate prejudice. The court of appeals affirmed. Petitioner then filed a notice to invoke the Supreme Court's discretionary jurisdiction on the ground that the court of appeal's decision below "expressly and directly conflicts with the decision of another district court of appeal or the Florida Supreme Court." Petitioner's jurisdictional brief, however, did not identify a conflict case but instead stated that the case "may present federal issues." The Supreme Court denied relief, holding that because Petitioner's jurisdictional brief failed to identify a jurisdictional basis for the Court to consider his case, he was not entitled to review. View "Mallet v. State" on Justia Law

by
The Supreme Court affirmed the order of the circuit court denying in part and dismissing in part Defendant's second successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that Defendant was not entitled to relief on his claim. In his second successive postconviction motion Defendant asserted that newly discovered evidence required that his conviction be overturned, that the State committed Brady and Giglio violations, and that his death sentence was unconstitutional because he was innocent of the murder. The circuit court denied relief. The Supreme Court affirmed, holding (1) all of Defendant's newly discovered evidence claims were either correctly rejected as untimely or based on inadmissible evidence; (2) each of Defendant's Giglio claims failed on the merits; (3) the lower court did not err in declining to take judicial notice of certain records; and (4) the circuit court did not err in summarily rejecting Defendant's claim that he is actually innocent. View "Dailey v. State" on Justia Law

by
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

by
The Supreme Court quashed the decision of the Third District on the issue of whether a defendant is entitled to a de novo sentencing proceeding after an appellate court determines that the trial court's initial downward departure sentence was not supported by legally sufficient findings, holding that the proper remedy upon reversal of a sentence due to the invalidity of a downward departure is resentencing de novo. Defendant pled guilty to four offenses and was placed on probation. The trial court subsequently revoked Defendant's probation and imposed a downward departure from what otherwise would have been the lowest permissible sentence under the Criminal Punishment Code (CPC). The Third District concluded that the departure was invalid and remanded for "resentencing within the sentencing guidelines." The Supreme Court quashed the Third District's decision, holding that on remand for resentencing due to the substantive invalidity of a downward departure, the trial court is permitted to impose a downward departure as long as the departure comports with the principles and criteria of the CPC. View "Shine v. State" on Justia Law

by
The Supreme Court held that through persistent filing of nonmeritorious requests for relief, Mark Jackson had abused the judicial process and, accordingly, directed the Clerk of Court to reject any future pleadings, documents, or other requests for relief submitted by Jackson unless such filings were signed by a member in good standing of The Florida Bar. Jackson - a pro se litigant - filed a petition to invoke the Supreme Court's discretionary jurisdiction. The Court denied Jackson's petition but expressly reserved jurisdiction to pursue possible sanctions against him. While the case was pending, Jackson filed several motions that were frivolous, without merit, or sought relief previously denied. The Supreme Court concluded that a sanction was necessary because, if not restrained, Jackson would continue to burden the Court with frivolous and meritless filings. View "Jackson v. State" on Justia Law

by
The Supreme Court ordered that the Clerk of Court reject any future pleadings, petitions, motions, documents, or other filings submitted by Larry R. Wetzel that were related to his criminal case, holding that that Wetzel has abused the judicial process and burdened the Court's limited judicial resources. Wetzel was charged with five counts of filing a false statement against real or personal property. Wetzel filed five pro se petitions with the Supreme Court seeking relief related to those criminal charges, each of which was accompanied by a plethora of rambling documents. Two of the petitions were voluntarily dismissed by Wetzel but the remainder were dismissed as unauthorized. Based on Wetzel's vexatious filing history, the Supreme Court issued an order directing him to show cause why he should not be prohibited from filing any further pro se documents in the Court related to his criminal case. Upon consideration of Wetzel's response, the Supreme Court concluded that he failed to show cause why sanctions should not be imposed. View "Wetzel v. State" on Justia Law

by
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