Justia Criminal Law Opinion Summaries

Articles Posted in Florida Supreme Court
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The Supreme Court affirmed the judgment of the circuit court summarily denying Appellant's third amended successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851 and denying his motion to correct illegal sentence filed pursuant to Fla. R. Crim. P. 3.800(a), holding that there was no error.Appellant was convicted of three counts of first-degree murder, two counts of arson, and grand theft. Appellant was sentenced to death for each murder. The Supreme Court affirmed. Appellant later filed the postconviction motion at issue and a rule 3.800(a) motion arguing that his death sentences were illegal. The circuit court summarily denied the postconviction motion and also denied his rule 3.800(a) motion. The Supreme Court affirmed, holding that Appellant's claims were not timely raised. View "Pittman v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court summarily denying Appellant's second successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851, holding that there was no error.The State charged Appellant with first-degree murder. Following a second trial, a jury found Defendant guilty and recommended a sentence of death. The Supreme Court reversed due to a jury selection error. On remand, a jury again found Defendant guilty. The trial court sentenced him to death. The Supreme Court affirmed, holding that the circuit court did not err in denying Appellant's newly discovered evidence and Brady claims. View "Valentine v. State" on Justia Law

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The Supreme Court affirmed the judgment of the trial court summarily denying Defendant's seventh motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the trial court did not err in summarily denying relief.The State charged Defendant with first-degree murder and other crimes. Defendant pled guilty to each of the charged offenses, and the trial court sentenced him to death. After the death sentence became final, Defendant sought postconviction relief in state and federal courts, without success. Defendant later brought the postconviction motion at issue on appeal arguing that the trial court's failure to conduct a hearing pursuant to Hall v. Florida, 572 U.S. 701 (2014), constituted reversible error. The Supreme Court affirmed, holding that Defendant could not succeed on his Hall-based intellectual disability claim, and therefore, the trial court did not err in summarily denying that claim. View "Thompson v. State" on Justia Law

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The Supreme Court sanctioned Petitioner, an inmate in state custody, holding that Petitioner failed to show cause why he should not be barred.Petitioner was convicted of first-degree murder and robbery with a gun or deadly weapon. Since 2009, Petitioner demonstrated a pattern of vexatious filing of meritless pro se requests for relief in this Court related to his case, including the pro se petition in the instant case, which the Supreme Court treated as a petition for writ of habeas corpus. The Supreme Court dismissed the petition and directed the clerk of court to reject any future pleadings or other requests for relief unless such filings are signed by a member in good standing of The Florida Bar. View "Rivera v. Dixon" on Justia Law

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The Supreme Court held that conviction on multiple counts under Fla. Stat. 316.062(2) stemming from a single crash involving multiple victims does not expose a defendant to multiple punishments for one offense in violation of constitutional double jeopardy protections.Under section 316.027, when a car crash results in the injury or death of "a person," the driver of a vehicle involved in the crash must stop and remain at the scene until fulfilling the requirements of Fla. Stat. 316.062, which requires the driver to provide identifying information to any injured person and the police and to render reasonable assistance to any injured person. Defendant was convicted of four violations of section 316.027(2), one violation for each victim of one crash. The court of appeal vacated two of Defendant's three convictions as violating double jeopardy principles. The Supreme Court quashed the decision below, holding (1) section 316.027(2) contemplates a per-crash-victim unit of prosecution rather than on a per-crash basis; and (2) therefore, Defendant's separate convictions for each crash victim were not multiple punishments for the same offense. View "State v. Johnson" on Justia Law

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The Supreme Court approved the holding of the court of appeal that Fla. Const. art. I, 14 does not prohibit the trial court the discretion at first appearance, upon a finding of probable cause that the defendant committed a crime punishable by capital punishment or life imprisonment, to defer ruling on bail and to detain the defendant for a reasonable time to conduct a "full" Arthur bond hearing, holding that there was no error.Defendant was arraigned on one count of robbery using a firearm or deadly weapon. After a hearing held pursuant to State v. Arthur, 390 So. 2d 717 (Fla. 1980) the trial court concluded that the evidence was sufficient to convict Defendant of unarmed robbery and granted him pretrial release and bail in the amount of $25,000. On appeal, Defendant argued that the first sentence of article 1, section 14 creates a two-step procedure. The court of appeals rejected this argument. The Supreme Court affirmed, holding that article I, section 14 does not prohibit a trial court from detaining a defendant beyond first appearance without setting release unless the court has made a preliminary finding that the proof of guilt is evident or the presumption is great. View "Thourtman v. Junior" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Billy Sheppard Jr.'s motion to vacate his conviction of first-degree murder and denied Sheppard's petition for a writ of habeas corpus, holding that the circuit court properly denied postconviction relief for all guilt claims and that Sheppard failed to establish that he was entitled to habeas corpus relief.Sheppard was convicted of first-degree murder and sentenced to death. Sheppard later filed a motion to vacate his conviction and sentence under Fla. R. Crim. P. 3.851. The circuit court granted a new penalty phase but denied Sheppard's claims as to the guilt phase of his trial. Sheppard appealed, raising claims relevant to the guilt phase, and filed a petition for writ of habeas corpus raising two claims of ineffective assistance of counsel. The Supreme Court affirmed the circuit court's order and denied Sheppard's petition for writ of habeas corpus, holding that Sheppard was not entitled to relief on any of his claims. View "Sheppard v. State" on Justia Law

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The Supreme Court granted Petitioner's petition for a writ of mandamus compelling the court of appeals to reinstate his appeal of a circuit court order denying him postconviction relief, holding that Petitioner did all that the text of the inmate filing rule required.Petitioner, an inmate convicted of second-degree murder, filed a pro se petition for postconviction relief under Fla. R. Crim. P. 3.850. The circuit court denied the petition. Petitioner appealed, but the court of appeals dismissed the appeal as untimely. Petitioner then filed for relief seeking a writ of mandamus compelling the court of appeals to reinstate his appeal. The Supreme Court granted the petition, holding that the court of appeals erred in not accepting Petitioner's notice of appeal as timely filed without a prison date stamp because the prison mail log produced by Petitioner indicated the notice was timely turned over to prison officials for mailing under Fla. R. App. P. 9.420(a)(2). View "Wade v. State" on Justia Law

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The Supreme Court affirmed Defendant's two first-degree murder convictions and two corresponding sentences of death, holding that Defendant was not entitled to relief on his allegations of error.After a trial, a jury found Defendant guilty of two counts of first-degree murder with a firearm. The jury rendered unanimous verdicts recommending a penalty of death on both murder counts, determining that the aggravating factors outweighed the mitigating circumstances. In this direct appeal, Defendant raised fifteen claims, including several challenges to the trial court's evidentiary rulings and to Florida's death penalty scheme. The Supreme Court affirmed Defendant's convictions for first-degree murder and his sentences of death, holding that Defendant failed to establish prejudicial error in any respect. View "Joseph v. State" on Justia Law

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The Supreme Court affirmed Defendant's sentences of death imposed in connection with his conviction for two counts of first-degree murder, holding that Defendant was not entitled to relief on his claims of error.After he was originally convicted and sentenced Defendant received a new penalty phase in light of Hurst v. State, 202 So. 3d 40 (Fla. 2016). Thereafter, Defendant was resentenced to death for both murders. The Supreme Court affirmed Defendant's sentences of death, holding (1) Defendant's jury unanimously found that each of five aggravating factors was proven beyond a reasonable doubt; (2) there was no error in allowing the State to amend its notice of aggravating factors; (3) the trial court did not err in permitting the introduction of victim impact evidence; and (4) Defendant was not entitled to relief on his remaining claims of error. View "McKenzie v. State" on Justia Law