Justia Criminal Law Opinion Summaries

Articles Posted in Florida Supreme Court
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The case involves Joshua Lyle Creller, who was charged with resisting an officer without violence and possession of a controlled substance, methamphetamine, following a 2018 traffic stop. Creller refused to comply with a K-9 officer’s command to exit his vehicle during the traffic stop for officer safety. After his arrest, methamphetamine was found on his person. Creller moved to suppress the evidence of its discovery.The trial court denied Creller’s motion to suppress, finding the State’s evidence credible. The court concluded that the officer's request for Creller to exit the vehicle was for officer safety and did not violate the Fourth Amendment’s prohibition of unreasonable searches and seizures. Creller was subsequently convicted by a jury. However, the Second District Court of Appeal reversed the conviction, holding that Creller was unlawfully seized in violation of the Fourth Amendment when the initial traffic stop transformed into a narcotics investigation for which no prior probable cause existed. The court certified conflict with the Fifth District Court of Appeal in State v. Benjamin, which reached the opposite conclusion.The Supreme Court of Florida disagreed with the Second District Court of Appeal's interpretation. The court held that the Fourth Amendment allows a K-9 officer to order a driver to exit a vehicle during a lawful traffic stop for officer safety reasons. The court concluded that the K-9 officer's command to Creller to exit the vehicle was reasonable and did not transform the traffic stop into a narcotics investigation. Therefore, the court quashed the decision of the Second District Court of Appeal and approved the decision of the Fifth District Court of Appeal in State v. Benjamin. View "State of Florida v. Creller" on Justia Law

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In 2015, Zachary Penna committed a series of violent crimes in Florida, including two murders. After his arrest, Penna was read his Miranda rights and initially invoked his right to counsel. However, during his hospitalization, Penna voluntarily initiated several conversations with Deputy Michael Nettles, during which he made incriminating statements. Penna was subsequently charged with several crimes, including two counts of first-degree murder. Before trial, Penna moved to suppress the statements made to Deputy Nettles, arguing that they were obtained in violation of Miranda. The trial court denied the motion, and Penna was found guilty on all counts and sentenced to life in prison.Penna appealed to the Fourth District Court of Appeal, which found that the statements during the first two conversations were not obtained in violation of Miranda. However, the court ruled that Deputy Nettles violated Miranda by failing to re-read Penna his Miranda rights prior to the final three conversations. The court relied on its own precedent, which had interpreted a previous Florida Supreme Court decision to require a full re-reading of Miranda warnings under the circumstances of this case. The court found that the error was not harmless, despite the overwhelming evidence of Penna’s guilt.The Supreme Court of Florida accepted the case for review. The court was asked to consider whether a defendant’s Fifth Amendment Miranda rights are automatically violated when an officer fails to re-read a Miranda warning following a defendant’s voluntary re-initiation of contact. The court held that there is no per se requirement that an officer remind or readvise a defendant of his Miranda rights. The court found that the Fourth District Court of Appeal had improperly expanded the requirements of Miranda and receded from its previous decision that had established a categorical rule requiring a full re-reading of Miranda warnings. The court remanded the case for reconsideration under the proper standard. View "State of Florida v. Penna" on Justia Law

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In 2024, the Supreme Court of Florida affirmed the convictions and death sentences of Everett Glenn Miller for the first-degree premeditated murders of Kissimmee Police Officers Matthew Baxter and Richard “Sam” Howard. In August 2017, Miller had interrupted a conversation Officer Baxter was having with three individuals, requesting the presence of a superior officer at the scene. After Sergeant Howard arrived, Miller shot both officers twice in the head from close range. At the time of his arrest later that night, Miller was found carrying two firearms, including the murder weapon.Prior to the murders, Miller, a former Marine, had been posting hateful anti-police and race-based comments on social media. At trial, Miller did not dispute that he had killed the officers, but his defense argued that premeditation was lacking and that the murders should be considered second-degree. The jury convicted Miller of two counts of first-degree premeditated murder and unanimously recommended death for each murder.Miller raised seven issues on appeal, including arguments about the admissibility of certain evidence, the qualifications of an expert witness, the presence of the cold, calculated, and premeditated (CCP) aggravating factor, and the constitutionality of Florida's capital punishment scheme. The court found no merit in any of these arguments and affirmed Miller's convictions and death sentences. View "Miller v. State of Florida" on Justia Law

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The Supreme Court of Florida held that multiple punishments can be imposed for distinct acts springing from successive impulses to violate a single criminal prohibition in the course of a single criminal episode. In this case, the Petitioner, David William Trappman, was convicted of battery of a law enforcement officer and aggravated battery of a law enforcement officer during a single encounter. The first conviction was a result of Trappman shoving an officer, and the second conviction came from Trappman siccing a pit bull on the same officer. Trappman argued that the protection against double jeopardy precluded his dual convictions and sentences as they were part of a single criminal episode. The court disagreed, concluding that the shoving of the officer and the subsequent siccing of the dog on the officer were distinct criminal acts for which separate punishments were properly imposed. The court disapproved of previous cases that failed to apply the distinct acts test, which focuses on successive impulses. View "Trappman v. State" on Justia Law

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In the case under consideration, the appellant, Leon Davis Jr., a man sentenced to death, appealed the circuit court's denial of his initial motion for postconviction relief and also petitioned for a writ of habeas corpus. The crimes in question involved murders that occurred at a gas station and convenience store in Polk County, Florida. Davis was sentenced to death following a bench trial, and his convictions and sentences were affirmed on direct appeal. In his appeal, Davis raised several issues, which included violations of the Giglio rule, the Brady rule, and claims of ineffective assistance of trial and appellate counsel.The Supreme Court of Florida concluded that Davis did not demonstrate any instances of counsel’s deficiency, and thus, there was no cumulative error analysis to conduct. The court also held that Davis failed to prove that the State knowingly presented false testimony or that the testimony was material, thereby negating his Giglio claim. With regard to the Brady claim, the court ruled that Davis failed to establish prejudice and that the Brady violation did not exist. The Supreme Court of Florida also denied Davis's habeas claim. Thus, the court affirmed the circuit court's denial of postconviction relief and denied Davis's petition for habeas corpus. View "Davis v. State" on Justia Law

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In the case at hand, a Florida prisoner, Leon Davis Jr., under sentences of death, appealed the denial of his initial motion for postconviction relief and also petitioned the Court for a writ of habeas corpus. The crimes involved in this postconviction appeal occurred on December 13, 2007, at the Headley Insurance Agency in Polk County. Davis was sentenced to death following a jury trial for committing robbery, binding two women with duct tape, pouring gasoline on them, and setting them on fire. One of the women was pregnant. The Supreme Court of Florida, after reviewing the case, affirmed the denial of postconviction relief and denied Davis’s habeas petition. The Court found that Davis had not demonstrated that his trial counsel was ineffective or that the trial court erred in not ordering a competency examination. The Court also found that Davis's habeas claim was procedurally barred because it was a repackaged version of one of his postconviction claims. View "Davis v. State" on Justia Law

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In 2024, the Supreme Court of Florida heard an appeal from Paul Glen Everett, a prisoner sentenced to death for first-degree murder, burglary, and sexual battery. Everett sought to have DNA testing conducted on 15 items that he claimed were linked to an acquaintance, Jared Farmer, potentially implicating Farmer in the crimes for which Everett was convicted. He argued that such testing could potentially result in his acquittal or a finding of guilt on a lesser offense. The circuit court denied Everett's motion, and Everett appealed that decision.Upon review, the Supreme Court affirmed the lower court's denial. The court found that Everett's motion did not meet the requirements set by Florida law, which necessitates a claim that the requested DNA testing "will exonerate the" defendant or "will mitigate the sentence." The Supreme Court also noted that Everett had confessed to the crimes, and his identity as the perpetrator was not in genuine dispute during his trial. The court rejected Everett's attempt to introduce new claims that his confession was false and that Farmer was involved in the crime. Even if DNA testing had shown Farmer's involvement, the court concluded there was no reasonable probability that Everett would have received a lesser sentence given the severity of his own admitted involvement. View "Everett v. State" on Justia Law

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In this case, the Supreme Court of Florida denied a petition brought forward by Leonard P. Gonzalez, Jr., who requested a review of a nonfinal order by the circuit court. Gonzalez was convicted of home-invasion robbery and two counts of first-degree murder, for which he was sentenced to death. The circuit court set aside his death sentences, but denied any further relief. Following changes in Florida's death-penalty laws, Gonzalez sought an order declaring that the amended statute does not apply in his case, arguing against its application as unconstitutional and inconsistent with the presumption that substantive statutes apply prospectively. The circuit court disagreed and ruled that the amended statute would apply at his upcoming penalty phase.Gonzalez then petitioned the Supreme Court of Florida, invoking its all-writs authority and authority to issue writs of prohibition, arguing against the circuit court's ruling that the new statute could be lawfully applied at his upcoming penalty phase. However, the Supreme Court of Florida determined that the relief sought is not available by way of prohibition or its all-writs authority. The court concluded that the circuit court has jurisdiction to conduct the new penalty phase and that its decision to apply the new statute does not affect this jurisdiction. The court also clarified that its all-writs provision does not add appellate jurisdiction and is restricted to preserving jurisdiction that has already been invoked or to protect jurisdiction that likely will be invoked in the future. As such, Gonzalez's petition was denied. View "Gonzalez v. State of Florida" on Justia Law

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The Supreme Court quashed in part the decision of the Fifth District Court of Appeal and remanded this case for resentencing proceedings, holding that the trial court committed harmful Alleyne error. See Alleyne v. United States, 470 U.S. 99, 114 (2013).During Defendant's criminal trial, the trial court made an Alleyne error and then purported to review its own decision to determine whether the Alleyne error was harmful. The Fifth District found harmful error, concluding that the only available remedy was to remand the case with instructions to resentence Defendant under a statutory provision that carried a lesser penalty. The Supreme Court upheld the Fifth District's ruling that the trial court committed harmful Alleyne error but quashed the decision to the extent it directed that only resentencing would be an appropriate remedy, holding that on remand after making an Alleyne error, a trial court is not foreclosed from empaneling a jury to make a factual determination that affects the legally-prescribed range of allowable sentences. View "State v. Manago" on Justia Law

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In this case arising from two unrelated episodes in which a Tallahassee police officer used lethal force in detaining a suspect after asserting self-defense the Supreme Court held that Marsy's Law, Fla. Const. art. I, 16(b)-(e), guarantees to no victim, including a police officer, the categorical right to withhold his or her name from disclosure to the public.After the City of Tallahassee proposed to release the law enforcement officers' names to the public, the Florida Police Benevolent Association sought an emergency injunction to prevent that from happening. The trial court denied the injunction and ordered that the names of the two officers be released. The First District Court of Appeal reversed, concluding that nothing in article I, section 16 excluded police officers or other government employees from the protections granted crime victims. The Supreme Court quashed the decision of the First District, holding that Marsy's Law did not preclude the City from releasing the two police officers' names under the circumstances of this case. View "City of Tallahassee v. Fla. Police Benevolent Ass'n" on Justia Law