Justia Criminal Law Opinion Summaries

The Supreme Court held that Petitioner failed to show cause why he should not be barred from filing further pro se requests for relief in the Supreme Court relating to certain case numbers and, accordingly, sanctioned him.Petitioner filed the instant petition for writ of error coram nobis challenging a conviction and sentence for assault. Because the writ of error coram nobis no longer exists in Florida, the Supreme Court dismissed the petition, expressly retained jurisdiction to consider the imposition of sanctions, and ordered Petitioner to show cause why he should not be prohibited from filing further pro se requests for relief with the Supreme Court. The Supreme Court held that, as a result of Petitioner’s extensive history of filing meritless pro se petitions and notices in the Court, sanctions should be imposed. The Court then directed the clerk of court to reject any future pleadings or other requests for relief filed by Petitioner unless such filings were signed by a member in good standing of The Florida Bar. View "Schofield v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s order denying, after an evidentiary hearing, Appellant’s sixth successive motion for postconviction relief based on a claim of newly discovered evidence, holding that Appellant was not entitled to relief on his claims.Appellant was convicted of first-degree murder and other crimes. Appellant was sentenced to death. The Supreme Court affirmed on appeal. Appellant later filed his sixth successive motion for postconviction relief based on newly discovered evidence. The newly discovered evidence was an affidavit executed by a Florida state prisoner, who attested that Appellant did not commit the crimes. The postconviction court denied relief after a one-day evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court (1) did not err in admitting an arrest record showing that the prisoner was arrested five days before Appellant’s offenses; (2) did not err in finding that certain testimony was not credible; and (3) did not misapply the standard set forth in Jones v. State, 591 So. 2d 911 (Fla. 1991) for newly discovered evidence. View "Sweet v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order summarily denying Appellant’s successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851.Appellant was convicted in 2002 of first-degree murder and other crimes. The jury unanimously recommended a sentence of death for the murder by a vote of twelve to zero. The Supreme Court affirmed. In 2017, Appellant filed a successive postconviction motion to vacate his death sentence in light of Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). The circuit court summarily denied the motion. The Supreme Court affirmed, holding that any Hurst error in this case was harmless beyond a reasonable doubt. View "Everett v. State" on Justia Law

The Supreme Court withdrew the opinion issued on January 22, 2018, and substituted this opinion in its place, reviewing Pressley Bernard Alston’s appeal of the circuit court’s order denying Alston’s motion filed pursuant to Fla. R. Crim. P. 3.851 and Alston’s petition for a writ of habeas corpus.Alston sought relief pursuant to 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, 202 So. 3d 40 (Fla. 2016). The Supreme Court affirmed the circuit court’s denial of relief and denied Alston’s habeas petition, holding that Alston’s waiver of postconviction proceedings and counsel precluded him from claiming a right to relief under Hurst. Moreover, even if Alston’s postconviction waiver did not preclude him from raising a Hurst claim, Hurst would not apply retroactively to Alston’s sentence of death, which became final in 1999. View "Alston v. State" on Justia Law

An indigent defendant who is represented by private counsel pro bono is entitled to file motions pertaining to the appointment and costs of experts, mitigation specialists, and investigators ex parte and under seal, with service to the Justice Administrative Commission and notice to the State’s attorney’s office, and to have hearing on such motions ex parte, with only the defendant and the Commission present.Defendant was convicted of offenses, including first-degree murder, that she committed when she was seventeen years old. After the United States Supreme Court decided Miller v. Alabama, 467 U.S. 460 (2012), the Supreme Court remanded Defendant’s case for resentencing. Prior to the resentencing hearing, Defendant’s pro bono counsel filed a motion for an ex parte hearing regarding the appointment of experts for the Miller juvenile resentencing hearing. The trial court denied the motion. The First District Court of Appeal denied Defendant’s petition for writ of certiorari but also certified a question to the Supreme Court. The Court answered as set forth above, quashed the First District’s decision, and remanded Defendant’s case for resentencing. View "Andrews v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s denial of Jason Walton’s motion to vacate sentences of death under Fla. R. Crim. P. 3.851 and denied Walton’s petition for writ of habeas corpus.Walton was convicted and sentenced to death for the murders of three individuals that occurred during the commission of a robbery and burglary. This appeal concerned Walton’s fourth successive postconviction motion, in which Walton asserted that changes in Florida’s capital sentencing law were part of the cumulative review of new discovered evidence. The postconviction court denied the motion. Walton appeal and also filed a petition for habeas relief. The Supreme Court affirmed the denial of postconviction relief, holding that Walton’s claim that a proper Swafford/Hildwin cumulative analysis requires consideration of all changes in the law that might apply if a new trial were granted, as well as Walton’s other claims, was meritless. The Court then denied habeas relief, holding that Hurst v. State, 202 So. 3d 40 (Fla. 2016), did not apply retroactively to Walton’s sentences of death. View "Walton v. State" on Justia Law

Defendant, a juvenile nonhomicide offender, was entitled to resentencing under Graham v. Florida, 560 U.S. 48 (2010), because the sentencing court did not make the required findings at Defendant’s sentencing hearing to comport with chapter 2014-220, Laws of Florida, and because Defendant’s sentence lacked any review mechanism.Defendant was convicted of one count of attempted felony murder and one count of attempted armed robbery for a crime he convicted when he was fifteen years old. Defendant was sentenced as an adult to thirty years’ imprisonment for the attempted felony murder and fifteen years’ imprisonment for the attempted armed robbery, to be served concurrently. Defendant’s sentence did not provide for judicial review. The Supreme Court ordered that Defendant be resentenced under the juvenile sentencing provisions in chapter 2014-220. View "Morris v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Appellant’s successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, in which Appellant claimed newly discovered evidence, ineffective assistance of counsel, Brady and Giglio violations, and violation of Hurst v. Florida, 136 S. Ct. 616, and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The postconviction court summarily denied Appellant’s claims. The Supreme Court affirmed the summary denial of Appellant’s successive motion for postconviction relief, holding (1) the evidence proffered by Appellant in support of his newly discovered evidence claim was not newly discovered evidence; and (2) Appellant’s remaining claims were without merit. View "Taylor v. State" on Justia Law

A local government has the authority under Fla. Stat. 316.0083(1)(a) to contract with a private third-party vendor to review and sort information from red light cameras, in accordance with the local government’s written guidelines, before sending that information to a trained traffic enforcement officer, who determines whether probable cause exists and a citation should be issued.Petitioner received a traffic citation based on images from a red light camera. Petitioner argued that the City of Aventura’s red light camera enforcement program was illegal because it included the use of a third-party agent to review images from the City’s red light cameras before sending them to City police to determine whether a traffic citation should be issued. The court of appeal held that the City did not violate the Mark Wandall Traffic Safety Program, see Fla. Stat. 316.0083(1)(a), which grants local governments’ traffic enforcement officers the power to issue citations for traffic infractions captured by red light cameras. The Supreme Court affirmed, holding that the City did not exceed its statutory authority in contracting with a vendor to review the red light camera images and that the City’s use of its own standards for determining whether a traffic infraction has occurred did not violate the uniformity principle set forth in chapter 316. View "Jimenez v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Appellant’s motion filed pursuant to Fla. R. Crim. P. 3.851, in which Appellant sought relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and this Court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). The jury in Appellant’s case recommended a sentence of death by a vote of ten to two. The trial court sentenced Appellant to death, and Appellant’s sentence became final in 1994. The Supreme Court held that Hurst did not apply retroactively to Appellant’s death sentence, and therefore, Appellant was not entitled to relief. View "Reaves v. State" on Justia Law