Justia Criminal Law Opinion Summaries

Articles Posted in Florida Supreme Court
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The Supreme Court approved the decision of the Fifth District Court of Appeal affirming the trial court's denial of Defendant's motion for discharge for expiration of speedy trial, holding that the Fifth District properly applied Melton v. State, 75 So. 2d 291 (Fla. 1954), and that an investigatory detention does not constitute an arrest for purposes of starting the speedy trial period in Fla. R. Crim. P. 3.191. At issue was how the term "arrest" should be defined for purposes of starting the speedy trial period set forth in Rule 3.191, Florida's procedural speedy trial rule. The Supreme Court adhered to Griffin v. State, 474 So. 2d 777 (Fla. 1985), which adopted the definition of arrest from Melton for purposes of determining when the speedy trial period begins, and held that the Fifth District did not err in determining that there was no speedy trial violation in this case. View "Davis v. State" on Justia Law

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The Supreme Court answered a question certified to it by the First District Court of Appeal by holding that an inquiry under Faretta v. California, 422 U.S. 806 (1975), is not invalid if the court does not explicitly inquire as to the defendant's age, experience, and understanding of the rules of criminal procedure. Petitioner was charged with drug-related offenses and allegedly violated his probation. Petitioner sought to waive his right to counsel. The trial judge discharged Petitioner's attorney, and Petitioner was found guilty of both charges. On appeal, Petitioner argued that the trial court conducted an insufficient Faretta colloquy because the court failed to ask questions about, inter alia, his age, health, and education. The First District held that the Faretta inquiry was adequate. The Supreme Court approved the holding below, holding that a Faretta colloquy is not rendered inadequate by the trial court's failure to inquire as to the defendant's age, experience, and understanding of the rules of criminal procedure. View "Hooks v. State" on Justia Law

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The Supreme Court quashed the decision of the Third District Court of Appeal concluding that Fla. Stat. 776.032(4) was a substantive change in the law and therefore did not apply retroactively, holding that section 776.032(4) is a procedural change in the law and applies to all Florida "Stand Your Ground" immunity hearings conducted on or after the statute's effective date. Section 776.032(4), which effective in June 2017 altered the burden of proof at pretrial immunity hearings under Stand Your Ground law, applies to pending cases involving criminal conduct committed prior to the effective date of the statute. In the instant case, Defendant's immunity hearing took place after the statute went into effect. The Third District concluded that section 776.032(4) did not apply retroactively, and therefore, the statute was inapplicable in this case. The Supreme Court quashed the decision below and remanded the case, holding (1) section 776.032(4) is a procedural change in the law and not categorically barred by Fla. Const. art. X, 9 from applying in pending cases; (2) the determination of whether a new procedure applies in a pending case generally depends on the posture of the case; and (3) applying section 776.032(4) in a pending case does not entail a retroactive application of the statute. View "Love v. State" on Justia Law

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The Supreme Court approved the result of the decision of the First District Court of Appeal affirming Defendant's conviction for attempted second-degree murder with a weapon where the jury was given an erroneous jury instruction on the lesser included offense of attempted voluntary manslaughter with a weapon, holding that the trial court's unobjected-to, erroneous jury instruction did not constitute fundamental error. On appeal, the First District concluded that the erroneous jury instruction did not constitute fundamental error because the Supreme Court abrogated the jury pardon doctrine. The Supreme Court affirmed, holding that fundamental error did not occur in this case because there was no error in the jury instruction on the offense of conviction, the evidence supported that offense, and Defendant's constitutional rights were not violated even if Defendant was deprived of an opportunity for partial jury nullification. View "Knight v. State" on Justia Law

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The Supreme Court affirmed the denial of Sparre's postconviction motion to vacate his conviction of first-degree murder and sentence of death filed under Fla. R. Crim. P. 3.851 and denied his petition for writ of habeas corpus, holding that Sparre was not entitled to relief. As to Sparre's appeal from the denial of his postconviction motion, the Supreme Court held (1) trial counsel was not ineffective, despite two instances in which counsel was deficient; (2) the trial court properly denied Sparre's claim that the cumulative effect of trial counsel's errors entitled him to relief; and (3) Sparre's claims that the postconviction court erred in three other respects were without merit. As to Sparre's habeas petition, the Court held that Sparre was not entitled to relief on his claims of ineffective assistance of appellate counsel. View "Sparre v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court summarily denying Appellant's successive motion for postconviction relief, holding that summary denial of the successive postconviction motion was appropriate in this case. Appellant was convicted of first-degree murder and sentenced to death. In his successive postconviction motion, Appellant claimed that he had newly discovered evidence of Brady and Giglio violations and that he was entitled to relief under Hurst v. State. 202 So. 3d 40 (Fla. 2016) and under changes to Florida's capital sentencing statute enacted after Hurst. The circuit court summarily denied the successive postconviction motion, concluding that the newly discovered evidence claim was procedurally barred and that the Hurst-related claims lacked merit. The Supreme Court affirmed, holding (1) the record conclusively refuted Appellant's newly discovered evidence claim; and (2) Hurst relief was not available to Appellant. View "Bogle v. State" on Justia Law

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The Supreme Court affirmed the judgment of the postconviction court denying Defendant's guilt phase claims in his initial postconviction motion filed under Fla. R. Crim. P. 3.851, holding that the postconviction court did not err in denying relief. Specifically, the Court held that the postconviction court did not err in denying Defendant's (1) claim alleging newly discovered evidence; (2) six claims alleging ineffective assistance of counsel; (3) claim alleging cumulative error where the alleged individual errors were without merit; and (4) claim alleging that he may be incompetent at the time of execution where a death warrant had not been issued in this case. View "Matthews v. State" on Justia Law

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The Supreme Court affirmed Defendant's sentence of death for the first-degree murder of Terrese Pernell Stevens, holding that Defendant was not entitled to relief on his allegations of error. Specifically, the Court held (1) the jury instructions were sufficient during the penalty phase; (2) the trial court did not err in concluding that the impaired capacity mitigating circumstance had not been proven; (3) the sentencing order was sufficient; (4) the trial court did not err when it found five mitigating circumstances were established but "not mitigating"; (5) Defendant's death sentence was proportionate; and (6) the trial court did not err in denying Defendant's motion to bar imposition of the death penalty due to intellectual impairment. View "Newberry v. State" on Justia Law

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The Supreme Court sanctioned Defendant by directing the clerk of court to reject any future pleadings or other requests for relief submitted by Defendant related to three criminal cases, unless such filings were signed by a member in good standing of The Florida Bar, holding that Defendant had abused the Court's limited judicial resources. Defendant, an inmate, filed a pro se petition to invoke the Supreme Court's all writs jurisdiction. The Supreme Court dismissed the petition and retained jurisdiction to pursue possible sanctions. The Court then found that Defendant failed to show cause why he should not be barred. Specifically, the Court found that Defendant demonstrated a pattern of vexatious filing of meritless pro se requests for relief in the Supreme Court. The Court then found that Defendant failed to show cause why sanctions should not be imposed and sanctioned Defendant accordingly. View "Baysen v. State" on Justia Law

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The Supreme Court affirmed the order of the trial court denying Defendant relief from his conviction and denied Defendant's habeas conviction, holding that Defendant was not entitled to relief. Defendant was found guilty of first-degree felony murder and robbery with a firearm or other deadly weapon. Defendant later moved for postconviction relief. The trial court vacated Defendant's death sentence and ordered a new penalty phase pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016). Defendant appealed the denial of his guilt phase claims and petitioned the Supreme Court for a writ of habeas corpus. In the appeal from the postconviction motion, the Supreme Court affirmed, holding that Defendant was not entitled to relief on his allegations of error. The Court then denied habeas relief, holding that appellate counsel was not ineffective on direct appeal. View "Jordan v. State" on Justia Law