Justia Criminal Law Opinion Summaries

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

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

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

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

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

In answering a question certified by the First District Court of Appeal the Supreme Court considered whether defense counsel's objection to a peremptory strike was properly renewed before the jury was sworn.The question in this case was whether a defendant who accepts a jury, but renewed a previously-raised objection to a state peremptory challenge after the challenged juror has been excused but before the jury is sworn, has waived that objection. The Supreme Court rephrased the question and answered the rephrased question in the negative, holding that a request for a standing objection to nonspecific things previously objected to in preliminary proceedings does not renew a specific objection to a peremptory challenge when the defense has prior to that request accepted the jury without reservation. View "State v. Ivey" on Justia Law

The Supreme Court declined to answer a question certified by the Fourth District Court of Appeal regarding whether, under the Fourth Amendment, a warrantless blood draw of an unconscious person incapable of giving consent may be pursuant to Fla. Stat. 316.1932(1)(c) so that the unconscious person can be said to have "consented" to the blood draw, holding that this case fell squarely within the rule announced in Mitchell v. Wisconsin, 139 S. Ct. 2525 (2019).The Wisconsin Supreme Court analyzed the Fourth Amendment issue using the "consent" framework of the statute. During the pendency of this appeal the United States Supreme Court considered a materially indistinguishable issue relating to a similar Wisconsin statute and vacated the Wisconsin Supreme Court's decision. The Supreme Court declined to address the certified question as framed, applied Mitchell, vacated the Fourth District's decision, and remanded, holding that because this case fell within the rule announced in Mitchell, the warrantless blood draw was legal. View "McGraw v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court summarily denying as untimely Appellant's successive postconviction motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Appellant's motion was time barred.In his motion, Appellant argued that a diagnosis of gender dysphoria was newly discovered evidence that he was incompetent to plead guilty to first-degree murder, to waive a penalty phase jury, and to waive postconviction proceedings and counsel. The Supreme Court affirmed the circuit court's summary denial of the motion, holding that Appellant's motion was both time barred and not based upon newly discovered evidence. View "Rodgers v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying John Mack Sketo Calhoun's motion to vacate his conviction of first-degree murder filed under Fla. R. Crim. P. 3.851 and denied Calhoun's petition for a writ of habeas corpus, holding that Calhoun was not entitled to relief.Specifically, the Supreme Court held (1) as to Calhoun's postconviction appeal, the circuit court properly denied relief as to Calhoun's newly discovered evidence claim, trial counsel was not ineffective during the guilt phase, and none of Calhoun's remaining claims warranted relief; and (2) as to Calhoun's habeas petition, Calhoun failed to demonstrate that appellate counsel was ineffective on direct appeal. View "Calhoun v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing in part and denying in part James Dailey's third successive motion for postconviction relief and also denied Dailey's motion for stay of execution and his petition for a writ of habeas corpus, holding that Dailey was not entitled to relief on any of his claims.Dailey was convicted of first-degree murder and sentenced to death. After his death warrant was signed, Dailey filed his third successive motino for postconviction relief, which the circuit court dismissed in part and denied in part. The Supreme Court affirmed the postconviction court's denial of relief and denied Dailey's habeas petition, holding (1) the circuit court properly rejected Dailey's claims that his execution would be unconstitutionally arbitrary; (2) the circuit court did not err in rejecting Dailey's claim that newly discovered evidence proved the State committed Brady and Giglio violations; (3) the circuit court did not err in denying Dailey's requests for certain public records; and (4) Dailey was procedurally barred from raising his claims in his habeas petition. View "Dailey v. State" on Justia Law