Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the order of the circuit court denying Defendant's motion to vacate his sentence of death under Fla. R. Crim. P. 3.851, holding that there was no constitutional infirmity in Defendant's sentence. Defendant was sentenced to death for the murder of Karen Slattery after his jury recommended this sentence by a vote of ten to two. Defendant's conviction and sentence of death for Slattery's murder was reversed and remanded for a new trial, which delayed the finality date of his conviction and sentence for that murder and made Defendant eligible for Hurst relief. Defendant was again convicted of the Slattery murder and given the same sentence. In a successive postconviction motion, Defendant sought relief from his death sentence pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The circuit court denied relief. The Supreme Court affirmed, holding that because Defendant's jury found that he committed first-degree murder and jury findings established the existence of two statutory aggravators, Defendant was eligible for the death penalty under the law in effect at the time of his crime. View "Owen v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death, holding that there was no reversible error in the proceedings below. Defendant pleaded guilty to first-degree murder. After a penalty phase, Defendant was adjudicated guilty of first-degree murder and sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in finding Defendant competent to proceed; (2) the trial court did not err in failing to order a new competency evaluation before the penalty phase began; (3) Defendant's death sentence was a proportionate penalty; (4) the trial court's finding that the murder was cold, calculated, and premeditated without pretense of moral or legal justification was supported by competent, substantial evidence; (5) there was sufficient evidence to justify the trial court's finding that the murder was especially heinous, atrocious, and cruel; (6) the trial court's questioning and Defendant's responses were sufficient to satisfy the requirement of a knowing, intelligent and voluntary plea; and (7) Defendant's remaining arguments on appeal were without merit. View "Santiago-Gonzalez v. State" on Justia Law

The Supreme Court instructed the Clerk of this Court to reject any future pleadings, petitions, documents, motions, or other filings submitted by Defendant relating to case number 86-038693, unless such filings are signed by a member of The Florida Bar in good standing, holding that through his persistent filing of frivolous, meritless and repetitive requests for relief, Defendant has abused the judicial process and burdened this Court's limited juridicial resources. Further, the Court found that Defendant's motion to reopen his direct appeal due to fraud or collusion occurring during his direct appeal proceedings was a frivolous proceeding brought before the Supreme Court by a state prisoner. View "Campbell v. State" on Justia Law

The Supreme Court dismissed Petitioner's petition for review of an unelaborated order from the Second District Court of Appeal striking Petitioner's brief as unauthorized, holding that this Court lacked jurisdiction to review the Second District's order and that this Court lacked discretionary review jurisdiction under the Florida Constitution to review this type of case. Petitioner filed a petition for writ of habeas corpus. The Second District Court of appeals issued an unelaborated order denying the petition. Petitioner subsequently filed a motion for rehearing and an amended motion to rehearing, along with an initial brief. The Second District denied the amended motion for rehearing and issued an order striking the brief. The Supreme Court dismissed petition for review, holding that this Court lacked jurisdiction to review the order. View "Wheeler v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Appellant's successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to postconviction relief based on his intellectual disability claim and on his claim seeking relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). In 1982, Appellant was convicted of first-degree murder, robbery with a firearm, and kidnapping. Appellant was sentenced to death for the murder, and the sentence of death became final in 1999. In 2017, Appellant filed a successive postconviction motion claiming that he was intellectually disabled and a claim seeking relief under Hurst. The circuit court summarily denied the motion, finding that Appellant's intellectual disability claim was time barred and that Hurst did not apply retroactively to Appellant's case. The Supreme Court affirmed, holding that the circuit court properly denied relief. View "Cave v. State" on Justia Law

The Supreme Court affirmed the decision of the postconviction court summarily denying Defendant's second successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that Defendant was not entitled to relief. In 1995, Defendant was convicted of first-degree murder, conspiracy to commit murder, auto theft, and petty theft. Defendant was sentenced to death for the murder. In 1998, the death sentence became final. In 2018, Defendant filed a second successive postconviction motion claiming that he was intellectually disabled. The Supreme Court affirmed the postconviction court's summary denial of Defendant's intellectual disability claim, holding that Defendant's argument lacked merit. View "Lawrence v. State" on Justia Law

The Supreme Court affirmed the decision of the circuit court summarily denying Petitioner's fourth postconviction motion filed under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in summarily denying Petitioner's Giglio claim and newly discovered evidence claim. In his motion, Petitioner raised claims based on a letter used by the United States Department of Justice that criticized portions of the of the testimony provided by an FBI forensic hair analyst during Petitioner's joint trial with a codefendant. The circuit court summarily denied the claims. The Supreme Court affirmed, holding (1) Petitioner's reliance on the letter to establish a Giglio violation was misplaced; and (2) the letter was not of such nature that it would probably produce an acquittal on retrial. View "McDonald v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Appellant's claim of ineffective assistance of counsel for failure to challenge a biased juror, holding that the postconviction court's finding that defense counsel had a reasonable, strategic basis for not challenging the juror was supported by competent, substantial evidence. Appellant was convicted of first-degree murder, kidnapping, and robbery. Appellant was sentenced to death for the murder. Appellant later filed a motion for postconviction relief, alleging, among other things, ineffective assistance of counsel for failure to challenge a biased juror. After the Supreme Court remanded the issue for an evidentiary hearing, the postconviction court denied the claims, finding that counsel had chosen not to challenge the juror as part of a reasonable trial strategy. The Supreme Court affirmed, holding that competent, substantial evidence supported the finding that counsel made a reasonable decision not to challenge the juror; and (2) this strategy was objectively reasonable from the perspective of believing that it would operate to Defendant's advantage in this particular trial. View "Patrick v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the trial court properly denied relief. In his postconviction motion, Appellant raised a claim relating to the legal name of one of his victims, to whom he had been married, and sought relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 S. 3d 40 (Fla. 2016). The trial court denied the motion. The Supreme Court affirmed, holding (1) Appellant's claim regarding the legal name of one of his victims was untimely and procedurally barred; and (2) Hurst relief did not apply to Appellant because he waived his right to a penalty phase jury. View "Valentine v. State" on Justia Law

The Supreme Court quashed the decision of the Fourth District Court of Appeal, holding that the party opposing a peremptory strike must make a specific objection to the proponent's proffered race-neutral reason for the strike, if the strike is contested, to preserve a claim that the trial court erred in concluding that the proffered reason was genuine. At issue was the proper procedure for preserving a challenge to the trial court's determination that the facially race-neutral reason proffered by the proponent of a peremptory strike was genuine under step three of Melbourne v. State, 679 So. 2d 759 (Fla. 1996). During the voir dire proceedings in Defendant's case, Defendant objected to the State's peremptory strike as to a prospective African-American juror but never argued that the State's proffered explanation was not genuine. The Fourth District reversed and remanded for a new trial, concluding that the trial court had failed to demonstrate compliance with the duty to determine the genuineness of the proffered race-neutral reason. The Supreme Court quashed the Fourth District's decision, holding that because Defendant did not make a specific objection to the State's proffered facially race-neutral reason for the strike Defendant failed to preserve his challenge to the trial court's step three genuineness determination. View "State v. Johnson" on Justia Law