Justia Criminal Law Opinion Summaries

The Supreme Court denied Petitioner's pro se petition for a writ of prohibition challenging the trial court's rulings in criminal cases and a separate civil case, holding that Petitioner failed to show cause why he should not be pro se barred for his repeated misuse of the Court's limited resources.Petitioner, an inmate whose most recent conviction was for possession of a controlled substance, began filing petitions in the Supreme Court in 2018 pertaining to several different criminal cases and a dependency case regarding his children. Petitioner filed the instant prohibition petition challenging the trial court's denial of a motion and seeking to dismiss the case. The Supreme Court denied the petition and directed Petitioner to show cause why he should not be barred from filing further pro se requests for relief. The Supreme Court then sanctioned Petitioner, holding that Petitioner had abused the Court's limited judicial resources. View "Hill v. State" on Justia Law

The Supreme Court denied Petitioner's petition for a writ of habeas corpus and then sanctioned him, holding that Petitioner failed to show cause why he should not be pro se barred.In 2006, Petitioner was sentenced to life imprisonment as a prison releasee reoffender on two counts of kidnapping, and the court of appeal affirmed. Since 2006, the Petitioner "engaged in a vexatious pattern of filing meritless requests for relief" in the Supreme Court pertaining to his convictions and sentences, none of which merited relief. In the instant habeas petition, Petitioner raised several claims relating to the circuit court's 2006 judgment and sentence. The Supreme Court denied the petition and directed Petitioner to show cause why he should not be barred from filing further pro se requests for relief. The Supreme Court sanctioned Petitioner as pro se barred, holding that Petitioner failed to show cause why he should not be sanctioned for his abusive conduct. View "Steiner v. Dixon" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of first-degree murder but set aside and his sentences of death for each murder, holding that Defendant was deprived of his right to "have the Assistance of Counsel for his defense" when the trial court put him to an improper choice at the beginning of the penalty phase proceedings.After the jury returned guilty verdicts for both first-degree murder charges the matter proceeded to the penalty phase. The jury unanimously recommended sentences of death. After a series of Spencer hearings, the trial court sentenced Defendant to death for each murder. The Supreme Court affirmed and remanded the case for a new penalty phase, holding (1) the trial court did not commit reversible error in its evidentiary rulings during Defendant's guilt phase proceedings; (2) Defendant's convictions were supported by competent, substantial evidence; but (3) Defendant's waiver of his right to counsel during the penalty phase was not knowing, intelligent, and voluntary, and Defendant was entitled to a new sentencing hearing based on the trial court's fundamental error in forcing him to abandon counsel during that phase. View "Figueroa-Sanabria v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding Defendant sane to be executed, holding that the record contained competent, substantial evidence to support the circuit court's determination that Defendant was sane to be executed.After considering all the evidence, the circuit court concluded that Defendant failed to establish by clear and convincing evidence that he was insane to be executed. The Supreme Court affirmed, holding that the circuit court (1) did not err in finding Defendant sane to be executed; and (2) did not abuse its discretion in denying Defendant's motion for a continuance. View "Owen v. State" on Justia Law

The Supreme Court approved the decision of the court of appeal affirming the trial court's denial of Defendant's motion to suppress eyewitness identifications resulting from an out-of-court police procedure, holding that the proper standard of review is abuse of discretion review and that the court of appeal correctly analyzed the merits under that standard.In denying Defendant's motion to suppress, the court of appeal applied the abuse of discretion standard of review to the trial court's ruling on the out-of-court identification by the eyewitness. On appeal, the court of appeal affirmed "[d]ue to the abuse of discretion standard of review." The Supreme Court approved the decision below, holding (1) abuse of discretion review is the proper standard; and (2) the trial court did not abuse its discretion in admitting the out-of-court identification. View "Alahad v. State" on Justia Law

The Supreme Court dismissed Petitioner's pro se petition for writ of mandamus and sanctioned him for his repeated misuse of the judicial system's resources, holding that Petitioner's petition was frivolous.Petitioner was convicted of robbery with a weapon and trafficking in stolen property and sentenced to life in prison as a Prison Releasee Reoffender (PRR). The Third District Court of Appeal reversed Petitioner's PRR sentence and remanded the case with instructions to impose a "guideline sentence." Since then, Petitioner filed various filings related to his convictions and sentences, including this pro se mandamus petition. The Supreme Court dismissed the mandamus petition and directed the Clerk of Court to reject any future pleadings or other requests for relief submitted by Petitioner unless such filings are signed by a member in good standing of The Florida Bar, holding that Petitioner's petition was frivolous and that Petitioner demonstrated a pattern of vexatious filing of meritless pro se requests for relief. View "Foley v. State" on Justia Law

The Supreme Court affirmed the sentence of death imposed at Defendant's second resentencing for first-degree murder, holding that the two issues raised by Defendant on appeal were foreclosed by this Court's jurisprudence.Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court subsequently granted Defendant two new penalty-phase proceedings, including the one at issue. In the instant penalty-phase proceeding, Defendant waived a penalty-phase jury, the presentation of mitigating evidence, and his presence. The trial court ultimately imposed a sentence of death. The Supreme Court affirmed, holding (1) Defendant's sentence did not violate the Eighth Amendment; and (2) Defendant's remaining arguments lacked merit. View "Orme v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's sixth successive motion for post-conviction relief under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in summarily denying the motion.Appellant was convicted of first-degree felony murder and armed robbery and was sentenced to death. Decades later, Appellant filed the sixth successive post-conviction motion at issue on appeal, arguing that two pieces of allegedly newly discovered evidence required extending the rationale in Roper v. Simmons, 543 U.S. 551 (2005), for barring the execution of defendants under the age of eighteen at the time of the offense to bar the execution of defendants under the age of twenty-one. The circuit court summarily denied relief. The Supreme Court affirmed, holding that the circuit court did not err in finding that Appellant's claim was untimely and that his request to extend Roper was meritless. View "Melton v. State" on Justia Law

The Supreme Court affirmed the orders of the circuit court summarily denying Appellant's second successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, denying his motion for a stay of execution, and sustaining objections to his public records requirements made under Fla. R. Crim. P. 3.852, holding that there was no error.After a retrial, a jury found Appellant guilty of first-degree murder, armed burglary, attempted sexual battery, and armed robbery and unanimously recommended a sentence of death. The trial court imposed the death sentence. On April 3, 2023 Governor Ron DeSantis signed Appellant's death warrant. Appellant filed a second successive motion for postconviction relief, alleging three claims. The circuit court summarily denied the motion. The Supreme Court affirmed the denial of Defendant's postconviction motion, as well as the circuit court's orders sustaining Appellant's objections to public records requests and denying a stay of execution, holding that Appellant was not entitled to relief. View "Barwick v. State" on Justia Law

The Supreme Court denied a pro se petition for writ of mandamus brought by Petitioner, a pretrial detainee in the custody of the Volusia County Jail, and sanctioned Petitioner as pro se barred.Petitioner engaged in what the Court described as "a vexatious pattern of filing meritless pro se requests for relief in the Court pertaining to several civil and criminal cases filed by or against him." The Supreme Court denied relief in each of his filing, including the current petition. The Supreme Court denied the petition and held that Petitioner failed to show cause why he should not be sanctioned for his abusive conduct. The Court thus directed the Clerk of Court to reject and future pleadings or other requests for relief submitted by Petitioner unless such filings were signed by a member in good standing of The Florida Bar. View "Sanders v. State" on Justia Law