Justia Criminal Law Opinion Summaries

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

The Supreme Court quashed the decision of the Second District Court of Appeal concluding that Defendant's dual convictions for driving under the influence (DUI) with serious bodily injury and driving while license suspended (DWLS) with serious bodily injury as to the same victim were prohibited, holding that Defendant's dual convictions were not prohibited.Relying on its decision in Kelly v. State, 987 So. 2d (Fla. 2d DCA 2008), the Second District concluded that Defendant's convictions violated the single homicide rule. The Supreme Court disagreed, holding (1) the appropriate analysis for whether dual convictions for DUI with serious bodily injury and DWLS with serious bodily injury are prohibited under the constitutional protection against double jeopardy is the same-elements test in Fla. Stat. 775.021; and (2) therefore, dual convictions for these offenses do not violate the constitutional prohibition against double jeopardy. View "State v. Marsh" on Justia Law

The Supreme Court affirmed Defendant's two sentences of death imposed during a resentencing that the Supreme Court ordered as a result of a Hurst v. State, 202 So. 3d 40 (Fla. 2016), error, holding that Defendant was not entitled to relief on his claims.Defendant was convicted of two counts of first-degree murder and other crimes and sentenced by a jury to death. The Supreme Court affirmed. Defendant later filed a motion for postconviction relief, which the circuit court denied. The Supreme Court vacated Defendant's death sentences due to Hurst error. At the conclusion of a new penalty phase trial, the resentencing jury voted to recommend that Defendant be sentenced to death for both of his murder convictions. The trial court followed the resentencing jury's recommendation and sentenced Defendant to death as to both counts. The Supreme Court affirmed, holding (1) even assumed that the trial court erred by limiting the scope of voir dire by restricting Defendant's use of a hypothetical question, any error was harmless; and (2) the trial court's other rulings with respect to voir dire were not improper. View "Hojan v. State" on Justia Law

The Supreme Court denied the State's petition seeking an extraordinary writ that would direct the circuit court to dismiss a resentencing proceeding and reinstate two previously vacated death sentences for the State or, alternatively, a writ of prohibition that would bar the circuit court from conducting the resentencing, holding that Defendant's vacated death sentences cannot be retroactively reinstated.In 2017, Defendant filed a successive postconviction motion seeking relief under Hurst v. State, 202 So. 3d 40 (Fla. 2016). The postconviction court granted Defendant a new penalty phase, scheduled to begin in 2020, and the State did not appeal the order granting relief. Before trial, the State filed a motion requesting that the circuit court dismiss the resentencing proceeding and maintain Defendant's sentences of death, seeking to apply the holding in State v. Poole, 297 So. 3d 487 (Fla. 2020), to Defendant's case. The circuit court denied the motion. Thereafter, the State filed its emergency all writs petition and petition for writ of prohibition. The Supreme Court denied relief, holding that a death sentence that was vacated by the postconviction court cannot be "reinstated" if the State never appealed the final order granting relief, the resentencing has not yet taken place, and the Supreme Court has since receded from the decisional law on which the sentence was vacated. View "State v. Jackson" on Justia Law