Justia Criminal Law Opinion Summaries

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

Matthew Lee Caylor was convicted of the 2008 first-degree murder, sexual battery, and aggravated child abuse of thirteen-year-old Melinda Hinson. Caylor, who was on the run from felony probation in Georgia for molesting a fourteen-year-old girl, committed the crimes at the Valu-Lodge Motel in Panama City, where Melinda was living with her family. Caylor confessed to the crimes, stating he murdered Melinda to avoid arrest and out of anger from his previous conviction. Physical and DNA evidence corroborated his confession.The jury convicted Caylor and recommended the death penalty by an eight to four vote. The Florida Supreme Court affirmed the convictions and sentences on direct appeal but granted a new penalty phase due to the nonunanimous jury recommendation, pursuant to Hurst v. State. During the new penalty phase, Caylor vacillated on waiving his rights to a jury, mitigation evidence, and his presence. Ultimately, he waived these rights, primarily to spare the victim’s family a lengthy process. The trial court accepted his waivers after a full colloquy.The Florida Supreme Court reviewed the case and affirmed the trial court's decisions. The court found that Caylor's post-penalty phase request to withdraw his jury waiver was untimely and made in bad faith to delay proceedings. The court also rejected Caylor's argument that his waiver was based on misinformation about the victim's mother's death, stating that his understanding of his rights at the time of the waiver was not affected by this information. Additionally, the court found no error in the trial court's handling of the mitigation waiver and upheld the trial court's findings on the aggravating factors. The Florida Supreme Court concluded that the aggravators outweighed the mitigators and affirmed Caylor's death sentence. View "Caylor v. State" on Justia Law

Robert Craft, a prisoner sentenced to death, appealed the circuit court's denial of his initial motion for postconviction relief under Florida Rule of Criminal Procedure 3.851. Craft was convicted of premeditated first-degree murder for strangling and beating to death his cellmate, Darren W. Shira, at Columbia Correctional Institution on May 16, 2018. Craft confessed multiple times and provided detailed accounts of the murder, including his premeditation and the methods he used. He was indicted on October 1, 2018, and expressed a desire to plead guilty and receive the death penalty. After being found competent to represent himself, Craft pled guilty and waived his right to a penalty-phase jury and mitigation.The trial court accepted Craft's guilty plea and sentenced him to death. The Florida Supreme Court affirmed his conviction and sentence on direct appeal. Craft then filed a motion to vacate his conviction and sentence on six grounds, including ineffective assistance of counsel and prosecutorial misconduct. The circuit court conducted a Huff hearing and ultimately denied all of Craft's claims.The Supreme Court of Florida reviewed the circuit court's decision and affirmed the denial of postconviction relief. The court found that Craft's claims of ineffective assistance of counsel were either not cognizable or without merit, as trial counsel's performance was not deficient. The court also determined that Craft's claims of prosecutorial misconduct were procedurally barred because they could have been raised on direct appeal. Additionally, the court rejected Craft's claim of cumulative error, as each individual claim failed. The court concluded that the postconviction court did not err in summarily denying Craft's motion. View "Craft v. State of Florida" on Justia Law

In 2004, John F. Mosley was convicted of the first-degree murders of his ten-month-old son, Jay-Quan, and the boy’s mother, Lynda Wilkes. Evidence presented at Mosley’s 2005 trial established that he strangled Wilkes, asphyxiated Jay-Quan in a garbage bag, and disposed of their bodies. Wilkes’s remains were recovered, but Jay-Quan’s body was never found. Mosley received a life sentence for Wilkes’s murder and a death sentence for Jay-Quan’s murder.The Florida Supreme Court twice vacated Mosley’s death sentence, most recently in 2022, due to procedural errors, including the trial court’s failure to address Mosley’s motion to represent himself. The case was remanded for a new Spencer hearing and sentencing. Upon remand, Mosley requested counsel, and the trial court again imposed a death sentence. Mosley appealed, raising two issues.The Supreme Court of Florida reviewed the case. Mosley’s first claim, seeking a new penalty phase due to alleged jury nullification, was deemed procedurally barred as it was not raised in his previous appeal. The second claim, regarding newly discovered evidence of the medical examiner’s impairment, was dismissed as untimely. The court noted that even if the claim were timely, it would not succeed because the evidence was not likely to produce an acquittal on retrial.The Supreme Court of Florida affirmed Mosley’s death sentence, concluding that the issues raised were not properly before the court and did not warrant relief. View "Mosley v. State" on Justia Law

In 1983, Kayle Barrington Bates was convicted of kidnapping, attempted sexual battery, armed robbery, and first-degree murder of Janet White. Bates attacked White in her office, forced her into the woods, and murdered her. He was found at the crime scene with the victim’s blood on his clothing, and other physical evidence linked him to the crime. Bates gave inconsistent confessions, and the jury recommended the death penalty, which the court imposed.Bates's case has undergone multiple appeals. The Florida Supreme Court affirmed his conviction but remanded for reconsideration of the death sentence. After resentencing, Bates was again sentenced to death, which was affirmed. In 1989, the Governor signed Bates’s death warrant, but the trial court stayed his execution and ordered a new sentencing hearing due to ineffective counsel. The jury again recommended the death penalty, and the circuit court imposed it, which was affirmed by the Florida Supreme Court. Bates later petitioned for habeas corpus, raising issues about jury selection, but relief was denied.Bates recently sought to interview a juror from his 1983 trial, claiming to have learned that the juror was related to the victim’s family. The postconviction court denied his motion under Florida Rule of Criminal Procedure 3.575, which requires such motions to be filed within 10 days of the verdict unless good cause is shown. Bates did not specify when he discovered the relationship, failing to establish good cause for the delay.The Supreme Court of Florida affirmed the postconviction court’s denial, holding that Bates did not meet the burden of showing good cause for the 40-year delay in seeking the juror interview. The court emphasized the importance of timely motions to ensure that facts are fresh and readily ascertainable. View "Bates v. State" on Justia Law

Matthew Dettle was charged and convicted of three felonies in Florida: using a computer to solicit a child for unlawful sexual conduct, traveling to meet a minor after such solicitation, and using a two-way communications device to facilitate a felony. His conviction for the third offense was vacated. Dettle argued that his remaining two convictions violated the Double Jeopardy Clause of the U.S. Constitution, which prohibits multiple punishments for the same offense.The First District Court of Appeal found that Dettle's convictions for traveling to meet a minor and unlawful use of a two-way communications device violated double jeopardy and vacated the latter conviction. However, it affirmed his convictions for solicitation and traveling, as they were based on separate illegal acts. Dettle's convictions became final in 2017. After the Florida Supreme Court's decision in Lee v. State, which held that courts should only consider the charging document to determine double jeopardy violations, Dettle sought retroactive relief under this new rule.The Supreme Court of Florida reviewed whether the rule in Lee should apply retroactively. The court concluded that Lee does not apply retroactively to cases that were already final when it was decided. The court reasoned that the rule in Lee is procedural, not substantive, and does not meet the high bar for retroactive application under either the Witt or Teague standards. Consequently, the court affirmed the decision of the First District Court of Appeal, denying Dettle's request for postconviction relief. View "Dettle v. State of Florida" on Justia Law

The case involves Leo L. Boatman, who was convicted and sentenced to death for the first-degree premeditated murder of William L. Chapman, a fellow inmate at Florida State Prison. The murder occurred on July 5, 2019, and was captured on multiple video cameras. Boatman, along with codefendant William E. Wells, attacked Chapman with a ligature and two shanks for approximately twelve minutes while other inmates watched. Boatman blocked the door to prevent correctional officers from intervening. Boatman later explained that the murder was a result of being denied a review to be released from Close Management confinement and that Chapman had disrespected him.The trial court found Boatman guilty of premeditated first-degree murder. During the penalty phase, Boatman waived the jury, and the judge sentenced him to death. The State presented evidence of Boatman’s prior violent felonies, while the defense presented testimony about Boatman’s traumatic upbringing and mental health issues. The trial court found four aggravating factors, including that the murder was especially heinous, atrocious, or cruel (HAC) and cold, calculated, and premeditated (CCP). The court also considered and weighed mitigating factors but ultimately imposed the death sentence.The Supreme Court of Florida reviewed the case and affirmed the conviction and death sentence. The court found that the evidence was sufficient to support the conviction and that the trial court did not err in its rulings, including denying Boatman’s motion to adjudicate him incompetent to proceed, denying his motion to disqualify the judge, and denying his motion to exclude certain evidence. The court also upheld the trial court’s findings of the CCP and HAC aggravators and rejected Boatman’s arguments regarding the constitutionality of Florida’s death penalty scheme and his claim that his serious mental illness should exempt him from the death penalty. View "Boatman v. State" on Justia Law