Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the postconviction court denying Appellant's initial postconviction motion filed under Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief on his allegations of error.Appellant was convicted of two counts of first-degree premeditated murder and one count of escape while being transported. The trial court sentenced Appellant to death. Appellant later filed a postconviction motion raising seven claims. The circuit court granted an evidentiary hearing on most of Appellant's claims and then denied the postconviction motion as to all claims. The Supreme Court affirmed, holding that the postconviction court did not err in denying Appellant's claims of newly discovered evidence, ineffective assistance of counsel, cumulative error, and a Brady violation. View "Morris v. State" on Justia Law

The Supreme Court approved the decision of the First District Court of Appeal dismissing Defendant's appeal of the denial of his motion filed under Fla. R. Crim. P. 3.800(a), holding that Defendant could not show that the denial of his rule 3.800(a) motion was in error.Defendant was convicted of armed robbery of a firearm and kidnapping to facilitate a felony and sentenced to concurrent life sentences for both counts. In his rule 3.800(a) motion, Defendant argued that his life sentences were illegal because the trial court failed to impose ten-year mandatory minimum sentences pursuant to Fla. Stat. 775.087(2). The postconviction court denied the motion, concluding that the sentencing judge's failure to impose the ten-year mandatory minimum sentences did not render Defendant's sentences illegal because he did not benefit from the error. The court of appeals affirmed. The Supreme Court affirmed, holding that Defendant could not show that the denial of his rule 3.800(a) motion resulted in harm that may be remedied on appeal. View "Earl v. State" on Justia Law

The Supreme Court answered in the affirmative a question certified to it by the Fifth District Court of Appeals and quashed the Fifth District's decision in this case, holding that the lowest permissible sentence as defined by Fla. Stat. 921.0024(2) is an individual minimum sentence and not a collective minimum sentence where there are multiple convictions subject to sentencing on a single scoresheet.Defendant was convicted of attempted first-degree murder and other crimes. The Fifth District reversed the attempted first-degree murder, and Defendant was resentenced for his remaining conviction. The Criminal Punishment Code Scoresheet indicated that the lowest permissible sentence (LPS) was 107.25 months. The trial court concluded that the LPS is an individual minimum sentence that must be applied to each offense if the LPS exceeds each individual statutory maximum sentence. The Fifth District reversed, ruling that the LPS is an individual minimum sentence that applies to each offense even though the LPS did not exceed the statutory maximum sentence for the primary offense. The Supreme Court quashed the Fifth District's decision, holding that the LPS is an individual minimum sentence that must be imposed when the LPS exceeds the statutory maximum sentence for each offense. View "State v. Gabriel" 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 the postconviction court did not err.Appellant filed a successive postconviction motion claiming that, based on the prosecutor's peremptory strike of a juror for allegedly racial reasons, he was entitled to relief under Flowers v. Mississippi, 139 S. Ct. 2228 (2019). The postconviction court denied the motion, finding it to be procedurally barred, untimely, and without merit. The Supreme Court affirmed, holding that the successive motion was procedurally barred and untimely. View "Willacy v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's second successive postconviction motion filed pursuant to Fla. R. Crim. P. 3.851, holding that the trial court properly denied postconviction relief.Appellant was convicted of first-degree murder and sentenced to death. In his second successive postconviction motion, Appellant raised four claims based on the retroactivity of Hurst v. State, 202 So, 3d 40 (Fla. 2016), Hurst v. Florida, 577 U.S. 92 (2016), and chapter 2017-1, Laws of Florida and asserted that his sentence violated the Eighth Amendment. The trial court denied relief. The Supreme Court affirmed, holding that Appellant's arguments on appeal were unavailing. View "Randolph v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's second successive postconviction motion filed under Fla. R. Crim. P. 3.851, holding that Appellant did not demonstrate that he was entitled to relief.In 1986, Appellant was convicted of two counts of first-degree murder and sentenced. The Supreme Court affirmed. In his second successive postconviction motion, Appellant claimed that he was entitled to a new trial because counsel conceded Appellant's guilt to first-degree murder without giving Appellant notice and an opportunity to object. Appellant based his claim on the Supreme Court's decision in McCoy v. Louisiana, 138 S. Ct. 1500 (2018). The trial court denied the motion. The Supreme Court affirmed, holding that McCoy did not entitle Appellant to relief. View "Harvey v. State" on Justia Law

The Supreme Court held that a defendant's potential designation as a prison releasee reoffender (PRR) under Fla. Stat. 775.082(9)(a)1. is not a sufficient collateral legal consequence to preclude dismissal of an appeal challenging a state prison sentence erroneously imposed pursuant to a trial court's dangerousness finding under section 775.082(1).The decision of the Fourth District Court of Appeal in this case expressly and directly conflicted with that of the First District Court of Appeal in Johnson v. State, 260 So. 3d 502 (Fla. 1st DCA 2018). The district courts reached separate conclusions as to whether a defendant's potential designation as a prison releasee reoffender is a sufficient collateral legal consequence precluding dismissal of such an appeal. The Supreme Court approved the Fourth District's decision and disapproved the First District's decision, holding that a defendant's potential PRR designation under section 775.082(9)(a)1. is not a sufficient collateral legal consequence flowing from a state prison sentence erroneously imposed pursuant to a trial court's dangerousness finding to preclude dismissal of an appeal as moot where the defendant has served the incarcerate portion of the sentence. View "Casiano v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's successive post conviction motion file pursuant to Fla. R. Crim. P. 3.851, holding that Appellant's claims failed.In 1983, Appellant was convicted of first-degree murder, sexual battery, burglary of a dwelling, and second-degree grand theft. Appellant was sentenced to death. Following the denial of his first three postconviction motions Appellant filed a third successive postconviction motion raising claims based on the retroactivity of Hurst v. Florida, 577 U.S. 92 (2016). The trial court denied relief. The Supreme Court affirmed, holding that the trial court did not err in denying Appellant's motion. View "Wright v. State" on Justia Law

The Supreme Court imposed sanctions upon Defendant, holding that, based on his persistent history of filing pro se petitions that were meritless or otherwise inappropriate for the Supreme Court's review, Defendant abused the judicial process and burdened the Court's limited judicial resources.This case was before the Supreme Court on Defendant's petition for a writ of mandamus. The Supreme Court denied the petition and, concurrently with the denial, expressly retained jurisdiction to pursue possible sanctions. The Court directed Defendant to show cause why he should not be barred from filing any further requests for relief. The Court held that Defendant's response failed to show cause why sanctions should not be imposed. View "Jackson v. State" on Justia Law

The Supreme Court answered in the negative a certified question asking whether the single homicide rule found in House v. State, 474 So. 2d 1193 (Fla. 1985), precludes separate convictions of vehicular homicide and fleeing and eluding causing serious injury or death that involve the same victim.Defendant stabbed his girlfriend and ran over her with a car, resulting in her death. During a high-speed chase with law enforcement officers after fleeing the scene, Defendant crashed into another vehicle, killing two passengers. Defendant was convicted of one count of first-degree murder with a weapon, three counts of fleeing or attempting to elude a law enforcement officer causing serious injury or death, and two counts of vehicular homicide. On appeal from the denial of Defendant's postconviction motion, the Fifth District Court of Appeals concluded that Defendant's convictions were prohibited under the single homicide rule. The Supreme Court quashed the Fifth District's decision, holding that Defendant's dual convictions for vehicular manslaughter and fleeing or eluding causing serious injury or death are not prohibited under the same-elements test codified in Fla. Stat. 775.021(4). View "State v. Maisonet-Maldonado" on Justia Law