Justia Criminal Law Opinion Summaries

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

The Supreme Court held that its 2017 judgment vacating on direct appeal Defendant's death sentence is final, that neither the Supreme Court nor the trial court can lawfully reinstate that sentence, and that, therefore, resentencing was required.In 2015, Defendant was sentenced to death for first-degree premeditated murder. In 2017, relying on the then-applicable rule of Hurst v. State, 202 So. 3d 40 (Fla. 2016), the Supreme Court vacated Defendant's death sentence and remanded for a new penalty phase proceeding. In 2020, the Supreme Court decided State v. Poole, 297 So. 3d 487 (Fla. 2020), in which the Court receded from Hurst. Because Defendant would have been constitutionality eligible for a death sentence under the rule of Poole the State asked the trial court to reinstate Defendant's death sentence. The trial court denied the State's motion. Thereafter, the State filed a petition arguing that reinstatement of Defendant's death sentence was required under Poole. The Supreme Court denied the petition, holding that the Court cannot reconsider its judgment vacating Defendant's death sentence and that the trial court also lacked the authority to reconsider the Supreme Court's final judgment vacating Defendant's death sentence. View "State v. Okafor" on Justia Law

The Supreme Court affirmed Defendant's two first-degree murder convictions and two corresponding sentences of death, holding that Defendant's assignments of error were unavailing.Specifically, the Supreme Court held (1) the trial court did not err in instructing on and finding the CCP aggravator and the HAC aggravator; (2) the trial court did not err in instructing on and finding the HAC aggravator; (3) Florida’s death penalty statute is constitutional; (4) the trial court did not abuse its discretion in rejecting Defendant's two proposed impairment mitigators; (5) the trial court did not err in allowing victim impact evidence; (6) the prosecutor’s penalty phase closing argument did not violate Defendant's constitutional rights; and (7) competent, substantial evidence supported Defendant's first-degree murder convictions. View "Colley v. State" on Justia Law

The Supreme Court affirmed Defendant's first-degree murder conviction and sentence of death, holding that any error in the proceedings below was not prejudicial.Defendant pleaded guilty to the first-degree murder of his cellmate. The trial court accepted the plea, finding that it was freely, voluntarily, knowingly and intelligently given. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding (1) the trial court erred in one aspect of how it handled mitigation, but the error did not prejudice Defendant; (2) the trial court did not fundamentally error by failing to determine beyond a reasonable doubt that the aggravating factors were sufficient to justify the death penalty; (3) the trial court’s failure to enter a written order finding Defendant competent to proceed after orally announcing its competency finding did not constitute fundamental error; and (4) Defendant's guilty plea was knowingly, intelligently, and voluntarily entered. View "Craft v. State" on Justia Law

The Supreme Court held that the conformity clause of Fla. Const. art. I, 17 precluded the Court from analyzing death sentences for comparative proportionality in the absence of a statute establishing that review.Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant's sentence of death. The trial court later vacated Defendant's death sentence and ordered a new penalty phase proceeding pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016). The trial court subsequently sentenced Defendant to death. On appeal, Defendant argued that his death sentence was disproportionate in comparison to other cases in which the Court upheld the imposition of the death penalty. The State urged the Court to recede from precedent holding that the Court must review the comparative proportionality of every death sentence because comparative proportionality review violates the conformity clause. The Supreme Court agreed, holding that the conformity clause expressly forecloses this court's imposition of a comparative proportionality review requirement that is predicated on the Eighth Amendment. View "Lawrence v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree murder and his sentence of death, holding that no error occurred in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion in denying Defendant's request for self-representation as equivocal; (2) the trial court did not abuse its discretion in denying Defendant's peremptory challenge to an African American juror; (3) the trial court did not err in instructing the penalty phase jury; (4) the trial court did not abuse its discretion by admitting statements made by Defendant's prior victim in support of the prior violent felony aggravator; (5) competent, substantial evidence supported the trial court's finding of the HAC aggravator and the CCP aggravator; (6) Craven’s death sentence was proportionate; and (7) the evidence was sufficient to support Defendant's conviction for first-degree murder. View "Craven v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Defendant's successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the circuit court properly denied relief.Defendant was found guilty of first-degree murder and was sentenced to death. In his successive postconviction motion, Defendant claimed that he was entitled to relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016), and that the indictment was defective because it failed to include aggravating factors. The circuit court denied relief. The Supreme Court affirmed, holding (1) this Court's decision in State v. Poole, 297 So. 3d 487 (Fla. 2020), foreclosed relief on Defendant's Hurst claims; and (2) Defendant's claim that the indictment was defective was procedurally barred. View "Lott v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Petitioner's third successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in dismissing the motion as untimely.Petitioner was convicted of first-degree murder, armed robbery, and armed burglary. Petitioner was sentenced to death. The Supreme Court affirmed the convictions and sentence. Petitioner later filed a third successive motion for postconviction relief, raising a claim of newly discovered evidence. The trial court dismissed the motion as untimely. The Supreme Court affirmed, holding that because Petitioner and his counsel failed to exercise diligence in pursuing the facts on which the claim was predicated, the trial court did not err in dismissing the motion. View "Dillbeck v. State" on Justia Law