Justia Criminal Law Opinion Summaries

Articles Posted in Florida Supreme Court
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The Supreme Court affirmed the postconviction court’s order denying Appellant’s motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief under the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and the Supreme Court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Specifically, The Supreme Court held that the Court’s prior denial of Appellant’s postconviction appeal raising similar claims was a procedural bar to the claim at issue in this appeal. Further, the Court held that Appellant’s claim did not entitle him to Hurst relief. Therefore, Appellant’s motion was properly denied. View "Finney v. State" on Justia Law

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The Supreme Court affirmed the postconviction court’s order denying Appellant’s motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief under the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and the Supreme Court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Appellant was convicted of first-degree murder and sentenced to death following the jury’s recommendation for death by a vote of eight to four. Appellant’s death sentence became final in 1990. The Supreme Court affirmed the postconviction court’s order denying relief, holding that Hurst did not apply retroactively to Appellant’s sentence of death. View "Duckett v. State" on Justia Law

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The Supreme Court reversed the postconviction court’s summary denial of Appellant’s claim of intellectual disability, raised pursuant to the United States Supreme Court’s decision in Hall v. Florida, 572 U.S. 701 (2014) and remanded for an evidentiary hearing but affirmed the denial of Appellant's claim seeking relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016), 137 S. Ct. 2161 (2017), holding that Appellant was entitled to an evidentiary hearing on his intellectual disability claim. Appellant was convicted of two counts of first-degree murder and sentenced to death for each of the murders. The Supreme Court affirmed. Appellant later filed the successive postconviction motion at issue in this appeal. The postconviction court summarily denied each claim. The Supreme Court held (1) Appellant was entitled to an evidentiary hearing on his Hall claim for the same reasons that the Court granted evidentiary hearings in Walls v. State, 213 So. 3d at 346 and Franqui v. State, 211 So. 3d 1026 (Fla. 2017); and (2) Hurst did not apply retroactively to Appellant’s sentences of death. View "Foster v. State" on Justia Law

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The Supreme Court affirmed Defendant’s convictions of first-degree murder and six sentences of death, holding that no reversible error occurred in the proceedings below and that each of the death sentences was appropriate. Specifically, the Supreme Court held (1) the trial court did not abuse its discretion when it declined Defendant’s request for self-representation; (2) there was no improper doubling of aggravators; (3) Defendant’s challenge to the constitutionality of the death penalty was procedurally barred; (4) Defendant’s guilty pleas were knowing, intelligent, and voluntary; and (5) each of Defendant’s death sentences was proportionate. View "Damas v. State" on Justia Law

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The Supreme Court affirmed the circuit court’s order denying in part and dismissing in part Appellant’s successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief on any of his claims. Appellant was convicted of first-degree murder, sexual battery with great force, and burglary with assault. The jury recommended a death sentence by a vote of eight to four, and the trial court accepted the recommendation. In his successive postconviction motion to vacate his death sentence, Appellant raised claims under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The circuit court summarily denied the claim. The Supreme Court affirmed, holding (1) Hurst and Hurst v. Florida did not apply to Appellant; and (2) Appellant was not entitled to relief on his other claims. View "Reese v. State" on Justia Law

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The Supreme Court approved in part and quashed in part the decision of the Second District Court of Appeal in this case and remanded the case for further proceedings, holding that the trial court erred in denying Appellant’s motion for a judgment of acquittal as to first-degree premeditated murder and that Appellant was entitled to resentencing. A jury found Appellant guilty of first-degree murder and other crimes. The court of appeal affirmed Appellant’s convictions and sentences. The Supreme Court approved in part and quashed in part the court of appeal’s decision, holding (1) because Appellant presented a prima facie case of self-defense and the State did not refute Appellant’s claim beyond a reasonable doubt, the trial improperly denied Appellant’s motion for a judgment of acquittal as to the first-degree premeditated murder count; (2) the trial court did not err in denying the motion as to the attempted murder count; and (3) Appellant was entitled to resentencing. View "Williams v. State" on Justia Law

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The Supreme Court affirmed the order of the postconviction court denying Appellant’s motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Hurst v. State, 202 So. 3d 40 (Fla. 2016), did not apply retroactively to Appellant’s sentence of death. Appellant was convicted of first-degree murder and sentenced to death. The jury recommended death by a vote of seven to five. Appellant’s death sentence became final in 1993. In his postconviction motion, Appellant sought relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst. The Supreme Court affirmed the postconviction court’s order denying relief, holding that Appellant was not entitled to relief under Hurst. View "Thompson v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Appellant’s motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding, among other things, that Appellant’s attorney was not ineffective for failing to investigate and present certain mitigation evidence. Appellant was convicted of kidnapping and first-degree murder and sentence of death. In her motion for postconviction relief Appellant raised fourteen initial claims and then amended her motion to add a Hurst claim. The trial court denied the motion in its entirety. The Supreme Court affirmed, holding that trial counsel’s performance was not deficient, the State did not commit a Giglio violation, and Appellant was not entitled to a new penalty phase under Hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State, 202 So. 3d 40 (Fla. 2016). View "Allen v. State" on Justia Law

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The Supreme Court affirmed the postconviction court’s order denying Appellant’s second successive motion to vacate his judgment of conviction of first-degree murder and sentence of death, holding (1) any error on the part of the postconviction court in failing to hold a case management hearing pursuant to Huff v. State, 622 So. 2d 982 (Fla. 1993), was harmless; and (2) the postconviction court did not err in summarily denying Appellant’s newly discovered evidence claims. In his second successive motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, Appellant alleged newly discovered evidence in the form of an exculpatory affidavit of a witness and new DNA evidence. The postconviction court denied the motion without conducting a case management conference. The Supreme Court affirmed, holding (1) Appellant’s due process rights were not violated by the postconviction court’s failure to hold a Huff hearing; and (2) the postconviction court did not err in summarily denying Appellant’s second successive postconviction motion. View "Taylor v. State" on Justia Law

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The Supreme Court quashed the decision of the Fifth Circuit Court of Appeal expressly declaring valid Fla. Stat. 775.082(10), holding that subsection (10) violates the Sixth Amendment to the United States Constitution. In the decision on review, the Fifth District expressly declared subsection (10) valid in the context of rejecting Defendant’s argument that her state prison sentence violated the Sixth Amendment because the jury did not find that she presented a danger to the public under section 775.082(10). Section 775.082(1) requires that a qualifying offender whose sentencing scoresheet totals twenty-two points or fewer be sentenced to a nonstate prison sanction unless the trial court makes written findings that a nonstate prison sanction could present a danger to the public. The Supreme Court quashed the decision below, holding that subsection (10) violates the Sixth Amendment because it requires the court, not the jury, to find the fact of dangerousness to the public that is necessary to increase the statutory maximum nonstate prison sanction. View "Brown v. State" on Justia Law