Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the circuit court’s order denying Appellant’s successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in summarily denying relief.Appellant was convicted of first-degree murder. The jury recommended death by a vote of nine to three. Appellant later filed a successive motion for postconviction relief arguing that the jury did not find all of the elements required to convicted him of “capital first-degree murder” and that his age of eighteen years old at the time of the murder should preclude the imposition of the death penalty. The trial court summarily denied relief. The Supreme Court affirmed, holding (1) Appellant’s guilt-phase jury considered all of the elements necessary to convict him of first-degree murder, a capital felony; and (2) Appellant was not entitled to relief on his claim that evolving standards of decency render his death sentence invalid under the Eighth Amendment. View "Foster v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying in part John William Campbell’s amended motion to vacate his conviction of first-degree murder and sentence of death filed under Fla. R. Crim. P. 3.851 and denied Campbell’s petition for a writ of habeas corpus, holding that Campbell was not entitled to the relief he sought.Campbell was convicted of first-degree murder and sentenced to death. Campbell later filed a motion to vacate judgment and sentence, raising several claims. The postconviction court granted one of the claims, awarding Campbell a new penalty phase based upon Hurst v. State, 202 So. 3d 40 (Fla. 2016), dismissed as moot Campbell’s remaining penalty-phase claims, and denied the remaining claims. Campbell appealed and filed a petition for writ of habeas corpus. The Supreme Court affirmed the postconviction court’s order and denied habeas relief, holding (1) the postconviction court properly denied relief on Appellant’s challenged claims; and (2) Appellant was not entitled to habeas relief on his claims of ineffective assistance of appellate counsel. View "Campbell v. State" on Justia Law

The Supreme Court reversed the order of the postconviction court denying Appellant’s motion filed pursuant to Fla. R. Crim. P. 3.851, holding that the judge who heard Appellant’s motion should have recused herself.Appellant was sentenced to death following a jury’s recommendation for death by a vote of eleven to one. Appellant’s sentence of death became final in 1990. In 2017, Appellant filed the successive postconviction motion at issue in this case seeking relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Judge Linda McCallum summarily denied the motion. Appellant then filed a motion to disqualify judge McCallum on the basis that she was an assistant state attorney working on capital cases at the time of Appellant’s postconviction proceedings. Judge McCallum denied the motion. The Supreme Court remanded this case for reassignment to another huge for evaluation of Appellant’s claims, holding that Judge McCallum should have granted Appellant’s motion to disqualify. View "Reed v. State" on Justia Law

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 Appellant was not entitled to relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016).Appellant was convicted of first-degree murder and sentenced to death. The death sentence was imposed following a jury’s recommendation for death by a vote of seven to five. Appellant’s death sentence became final in 1997. In 2017, Appellant filed the successive motion for postconviction relief at issue in this case, seeking relief pursuant to Hurst. The postconviction court summarily denied the motion. The Supreme Court affirmed, holding that Hurst did not apply retroactively to Appellant’s sentence of death, and therefore, Appellant was not entitled to the relief he claimed. View "Mungin v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s summary denial of Appellant’s successive postconviction motion to vacate his sentences of death under Fla. R. Crim. P. 3.851, holding that the record conclusively demonstrated that Appellant was not entitled to relief.In 1986, Appellant was convicted of two counts of murder. Appellant’s death sentences became final in 1989. In the instant appeal, Appellant argued that the postconviction court erred in denying his intellectual disability claim without holding an evidentiary hearing and in denying his claim under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court affirmed, holding that the record conclusively showed that Appellant’s intellectual disability claim was untimely and that Appellant’s Hurst claim did not entitle him to relief. View "Harvey v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant’s successive motion for postconviction relief under Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief pursuant to Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), nor was he entitled to relief on his other claims.Appellant was convicted of the 1992 first-degree murder of his wife. The jury recommended a death sentence by a vote of seven to five. The trial court imposed a sentence of death. Appellant later filed a successive motion to vacate his death sentence in light of Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst. The circuit court summarily denied the motion. The Supreme Court affirmed, holding that because Appellant’s sentence became final prior to Ring v. Arizona, 536 U.S. 584 (2002), Appellant was not entitled to Hurst relief. View "Spencer v. State" on Justia Law

The Supreme Court vacated Defendant’s death sentence and remanded this case to the trial court for a new penalty phase, holding that the error pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016), was not harmless beyond a reasonable doubt.Defendant was convicted of first-degree murder of a law enforcement officer and other crimes. The jury recommended a sentence of death by a vote of nine to three on the murder charge. The trial court imposed a death sentence on the murder charge and lesser sentences on the other charges. Defendant appealed, arguing that he was entitled to a new penalty phase pursuant to Hurst. The Supreme Court agreed, vacated Defendant’s death sentence but affirmed his convictions and sentences on all lesser charges, holding that Hurst-related precedent required reversal of Defendant’s death sentence. View "Tisdale v. State" on Justia Law

The Supreme Court approved the decision of the First District Court of Appeal affirming the trial court’s denial of Defendant’s motion to vacate his 1000-year sentences with parole eligibility pursuant to Fla. R. Crim. P. 3.850, holding that Defendant’s sentences did not violate the categorical rule of Graham v. Florida, 560 U.S. 48 (2010).Defendant committed nonhomicide crimes at age seventeen and received concurrent sentences of 1000 years. The Parole Commission, after eleven review hearings, calculated a presumptive parole release date of 2352. After the United States Supreme Court decided Graham and Miller v. Alabama, 567 U.S. 460 (2012), Defendant filed a motion to vacate his sentences pursuant to Fla. R. Crim. P. 3.850, arguing that his sentences violated the Eighth Amendment as delineated in Graham. The trial court denied the motion, and the First District Court of Appeal affirmed. The Supreme Court affirmed, holding that Defendant was not entitled to resentencing under chapter 2014,200, Laws of Florida. View "Franklin v. State" on Justia Law

The Supreme Court approved the decision of the Fourth District Court of Appeal in this appeal concerning the rule of completeness codified in the Florida Evidence Code and a related issue concerning the rule of evidence authorizing the impeachment of hearsay declarants.The Court held (1) a defendant is not permitted to require the State under Fla. Stat. 90.108(1) - the statutory rule of completeness - to introduce into evidence the entire video recording of the defendant’s statement to police when the State has questioned a detective of direct examination concerning inculpatory statements of the defendant unless the State introduces any portion of the recorded statement into evidence; and (2) the State is permitted to impeach a defendant under Fla. Stat. 90.806(1), which authorizes attacking the credibility of a hearsay declarant, whenever the defendant introduces through cross-examination hearsay exculpatory statements of the defendant. View "Nock v. State" on Justia Law

The Supreme Court approved the decision of the First District Court of Appeal concluding that an automobile can be a weapon for purposes of Florida’s reclassification statute, Fla. Stat. 775.087(1), holding that an automobile is a weapon under section 775.087(1) if it is used to inflict harm on another and that it is a question of fact for the jury to determine whether an automobile or other object was used as a weapon by the defendant.Defendant was convicted of manslaughter with a weapon, where the weapon supporting the charge was an automobile, and leaving the scene of a crash involving death. On appeal, Defendant argued that the trial court erred in allowing his manslaughter conviction to be reclassified from a second-degree felony to a first-degree felony for using a weapon pursuant to section 775.087(1). The First Circuit disagreed and upheld the conviction. The Supreme Court approved the First District’s conclusion that an automobile can be a weapon for purposes of the reclassification statute, holding that any object used or intended to be used to inflict harm on another constitutes a weapon within the meaning of the statute. View "Shepard v. State" on Justia Law