Justia Criminal Law Opinion Summaries

The Supreme Court quashed the decision of the Fourth District Court of Appeal affirming the denial of Defendant’s motion to suppress and remanded this case to the district court with instructions that the case be remanded for a new trial without introducing portions of statements made after Defendant unequivocally invoked his right to silence, holding that the statements were produced as a result of a Miranda violation, and the error was not harmless.Defendant, who was convicted of first-degree murder and attempted first-degree murder, appealed the denial of his motion to suppress his confession on the basis that detectives had violated his right against self-incrimination and right to counsel. The Fourth District affirmed. The Supreme Court quashed the Fourth District’s decision, holding (1) a detective’s statements after Defendant unequivocally invoked his right to silence constituted interrogation; (2) the State was unable to meet its burden of demonstrating that Defendant’s subsequent Miranda waiver was voluntarily made; and (3) therefore, the trial court erred in admitting Defendant’s confession. View "Shelly v. State" on Justia Law

The Supreme Court denied Petitioner’s petition for writ of habeas corpus, denied his motion for a stay of execution, and denied his request for oral argument as moot, holding that Petitioner was not entitled to relief on his claim that he was entitled to vacate of his death sentence or resentencing.In his petition, Petitioner, a prisoner under sentence of death and under an active death warrant, argued that an amendment to Fla. Const. art. X, 9, which was approved by Florida voters on November 6, 2018, warranted vacatur of his death sentence or resentencing under revised Fla. Stat. 921.141. The Supreme Court held that Petitioner was not entitled to relief because (1) the amendment will not go into effect until January 8, 2019; and (2) even if the amendment were in effect, it does not change the law applicable to Petitioner’s conviction and death sentence. View "Jimenez v. Jones" on Justia Law

The Supreme Court exercised jurisdiction over Petitioner’s all writs petition and denied it, holding that Petitioner, a prisoner under an active death warrant, was precluded from making new filings in the circuit court challenging his death sentence or warrant, or his convictions, without leave of this Court.Specifically, the Supreme Court held (1) the scheduling order in this case, both as issued and as amended, prohibited the filing of new claims in the circuit court after the deadline set forth in that order; (2) the issuance of a mandate in two postconviction appeals that ensued after the issuance of Petitioner’s death warrant did not render the scheduling order inoperable; (3) Petitioner’s challenge to this Court’s authority to issue or enforce death lines set forth in its post-warrant scheduling order was without merit. View "Jimenez v. Bondi" on Justia Law

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