Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the circuit court's order summarily denying Defendant's successive emotion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the circuit court properly denied Defendant's claims.Defendant was convicted of first-degree felony murder, aggravated child abuse, and sexual battery and sentenced to death for first-degree felony murder. Defendant later filed a successive postconviction motion claiming that the State committed Giglio and Brady violations. The circuit court summarily denied the motion. The Supreme Court affirmed, holding that the circuit court did not err in summarily denying Defendant's Giglio claim and properly denied Defendant's Brady claim. View "Davis v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Defendant's fifth successive postconviction motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Defendant was not entitled to postconviction relief.Defendant was convicted of first-degree murder and robbery and sentenced to death. In his fifth successive postconviction motion, Defendant argued that his counsel conceded guilt without his consent and that the error was structural. The trial court dismissed the motion on the grounds that it was untimely and that, even if it had been timely, it was without merit. The Supreme Court affirmed, holding that Defendant did not state a facially sufficient claim. View "Atwater v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Defendant's second successive motion for post conviction relief, holding that Defendant was not entitled to postconviction relief.Defendant was convicted of first-degree felony murder and burglary with an assault. The trial judge imposed the death sentence, and the Supreme Court affirmed. Defendant later filed a second successive motion for postconviction relief under Fla. R. Crim. P. 3.851 claiming 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 Atkins v. Virginia, 536 U.S. 304 (2002). The trial court summarily denied the motion. The Supreme Court affirmed, holding (1) Defendant was not entitled to retroactive Hurst relief; and (2) Defendant's intellectual disability claim was untimely. View "Freeman v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily dismissing as untimely Petitioner's successive motion for postconviction relief, holding that the record conclusively established that Petitioner was not entitled to relief.In 1993, Petitioner was convicted of first-degree murder and sentenced to death. The Supreme Court twice affirmed and twice remanded for resentencing at a new penalty phase. At Petitioner's third penalty phase, he was sentenced to death, and the Supreme Court affirmed. At issue was Petitioner's third successive motion for postconviction relief under Fla. R. Crim. P. 3.851, filed on May 10, 2019. The circuit court dismissed the petition as untimely under rule 3.851(d)(2)(B). The Supreme Court affirmed without addressing the ruling that Petitioner's motion was untimely, holding that the record conclusively refuted Petitioner's allegation that trial counsel conceded Petitioner's guilt at trial. View "Merck v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court summarily denying Appellant's successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the postconviction court properly denied relief.Specifically, the Supreme Court held (1) Appellant was not entitled to postconviction relief based on his intellectual disability claim because Hall v. Florida, 572 U.S. 701 (2014), does not apply retroactively; and (2) Appellant was not entitled to relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016) because, during Appellant's trial, the requirement that a jury unanimously find a statutory aggravating circumstance beyond a reasonable doubt was satisfied. View "Poole v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Defendant's motion to vacate his sentence of death under Fla. R. Crim. P. 3.851, holding that there was no constitutional infirmity in Defendant's sentence.Defendant was sentenced to death for the murder of Karen Slattery after his jury recommended this sentence by a vote of ten to two. Defendant's conviction and sentence of death for Slattery's murder was reversed and remanded for a new trial, which delayed the finality date of his conviction and sentence for that murder and made Defendant eligible for Hurst relief. Defendant was again convicted of the Slattery murder and given the same sentence. In a successive postconviction motion, Defendant sought relief from his death sentence pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The circuit court denied relief. The Supreme Court affirmed, holding that because Defendant's jury found that he committed first-degree murder and jury findings established the existence of two statutory aggravators, Defendant was eligible for the death penalty under the law in effect at the time of his crime. View "Owen v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death, holding that there was no reversible error in the proceedings below.Defendant pleaded guilty to first-degree murder. After a penalty phase, Defendant was adjudicated guilty of first-degree murder and sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in finding Defendant competent to proceed; (2) the trial court did not err in failing to order a new competency evaluation before the penalty phase began; (3) Defendant's death sentence was a proportionate penalty; (4) the trial court's finding that the murder was cold, calculated, and premeditated without pretense of moral or legal justification was supported by competent, substantial evidence; (5) there was sufficient evidence to justify the trial court's finding that the murder was especially heinous, atrocious, and cruel; (6) the trial court's questioning and Defendant's responses were sufficient to satisfy the requirement of a knowing, intelligent and voluntary plea; and (7) Defendant's remaining arguments on appeal were without merit. View "Santiago-Gonzalez v. State" on Justia Law

The Supreme Court instructed the Clerk of this Court to reject any future pleadings, petitions, documents, motions, or other filings submitted by Defendant relating to case number 86-038693, unless such filings are signed by a member of The Florida Bar in good standing, holding that through his persistent filing of frivolous, meritless and repetitive requests for relief, Defendant has abused the judicial process and burdened this Court's limited juridicial resources. Further, the Court found that Defendant's motion to reopen his direct appeal due to fraud or collusion occurring during his direct appeal proceedings was a frivolous proceeding brought before the Supreme Court by a state prisoner. View "Campbell v. State" on Justia Law

The Supreme Court dismissed Petitioner's petition for review of an unelaborated order from the Second District Court of Appeal striking Petitioner's brief as unauthorized, holding that this Court lacked jurisdiction to review the Second District's order and that this Court lacked discretionary review jurisdiction under the Florida Constitution to review this type of case.Petitioner filed a petition for writ of habeas corpus. The Second District Court of appeals issued an unelaborated order denying the petition. Petitioner subsequently filed a motion for rehearing and an amended motion to rehearing, along with an initial brief. The Second District denied the amended motion for rehearing and issued an order striking the brief. The Supreme Court dismissed petition for review, holding that this Court lacked jurisdiction to review the order. View "Wheeler v. State" 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 Appellant was not entitled to postconviction relief based on his intellectual disability claim and on his claim seeking relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016).In 1982, Appellant was convicted of first-degree murder, robbery with a firearm, and kidnapping. Appellant was sentenced to death for the murder, and the sentence of death became final in 1999. In 2017, Appellant filed a successive postconviction motion claiming that he was intellectually disabled and a claim seeking relief under Hurst. The circuit court summarily denied the motion, finding that Appellant's intellectual disability claim was time barred and that Hurst did not apply retroactively to Appellant's case. The Supreme Court affirmed, holding that the circuit court properly denied relief. View "Cave v. State" on Justia Law