Justia Criminal Law Opinion Summaries

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). Appellant was convicted by a jury of two counts of first-degree murder. The jury recommended a sentence of death for each count, one by a vote of ten to two and the other by a vote of twelve to zero. The trial court subsequently sentenced Appellant to death on both counts. The Supreme Court affirmed, holding that Hurst did not apply retroactively to Appellant’s sentences of death, which became final in 1995. View "Jones v. State" on Justia Law

The Supreme Court directed the clerk of court to reject any future pleadings or other requests for relief submitted by Petitioner that pertained to two particular cases unless such filings were signed by a member in good standing of The Florida Bar. In addition, the Court found that the petition filed by Petitioner in this case was a frivolous proceeding brought before the Court by a state prisoner.Here, Petitioner, an inmate in state custody, filed a pro se petition to invoke the Supreme Court’s all writs jurisdiction. The Supreme Court dismissed the petition and expressly retained jurisdiction to pursue possible sanctions against him. The Supreme Court sanctioned Petitioner, who abused the judicial process and burdened the Court’s limited resources with repeated requests that were either frivolous or devoid of merit. View "Woodson v. State" on Justia Law

The Supreme Court withdrew its opinion issued on January 24, 2018 in this case and substituted this opinion in its place, holding that the circuit court properly denied Appellant’s motion filed pursuant to Fla. R. Crim. P. 3.851.Appellant’s motion sought relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and this court’s decision on remand in Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court held that Appellant’s valid waiver of postconviction proceedings and counsel in 2008 precluded him from claiming a right to relief under Hurst. Moreover, even if Appellant’s postconviction waiver did not preclude him from raising a Hurst claim, Hurst would not apply retroactively to Appellant’s sentence of death. View "Trease v. State" on Justia Law

In this appeal from a criminal conviction the Supreme Court affirmed in part and quashed in part the decision of the Second District Court of Appeal affirming Appellant’s convictions and sentences, holding that, based on the State’s concession, Appellant was entitled to resentencing pursuant to chapter 2014-220, Laws of Florida, and to resentencing pursuant to this Court’s decision in Williams v. State, 186 So. 3d 989 (Fla. 2016).A jury found Appellant guilty of first-degree premeditated murder and theft. The Second District affirmed. The Supreme Court held (1) the trial court properly denied Defendant’s motion for judgment of acquittal; and (2) where the State conceded that Appellant was entitled to resentencing, the case is remanded with instructions to remand to the trial court for resentencing. View "Williams v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s order denying Appellant relief on his successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851 in which Appellant sought to vacate his death sentence pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016).Appellant, an inmate at Tomoka Correctional Institution, was convicted and sentenced to death for the first-degree murder of a correctional officer. This appeal concerned Appellant’s first successive motion for postconviction relief raising claims under Hurst. The Supreme Court affirmed the denial of relief, holding (1) Appellant’s argument that the stricken cold, calculate, and premeditated aggravator in his case was sufficient to receive Hurst relief failed because any error was harmless beyond a reasonable doubt; (2) Appellant’s subclaims failed on the merits or were duplicative; (3) Appellant’s sentence did not violate the Eighth Amendment; and (4) Appellant’s claim that he was denied his right to a proper indictment because the grand jury indictment in his case did not list the aggravators failed. View "Hall v. State" on Justia Law

A defendant who claims that the offense as charged in the information is barred by the statute of limitations must raise the issue in the trial court in order to preserve the issue for direct appeal.On appeal from his convictions for burglary of a dwelling with the intent to commit sexual battery or robbery and sexual battery committed with possession of a firearm, offenses that occurred more than twenty years earlier, Defendant argued for the first time that the prosecution for armed burglary was subject to the four-year limitations period provided in Fla. Stat. 775.15(2)(a). The Third District Court of Appeal certified a question of law to the Supreme Court as a question of great public importance. The Supreme Court answered by holding that a defendant must raise a claim that conviction of a charged offense violates the statute of limitations in the trial court to preserve the issue for direct appeal. View "State v. Smith" on Justia Law

A defendant who claims that the offense as charged in the information is barred by the statute of limitations must raise the issue in the trial court in order to preserve the issue for direct appeal.On appeal from his convictions for burglary of a dwelling with the intent to commit sexual battery or robbery and sexual battery committed with possession of a firearm, offenses that occurred more than twenty years earlier, Defendant argued for the first time that the prosecution for armed burglary was subject to the four-year limitations period provided in Fla. Stat. 775.15(2)(a). The Third District Court of Appeal certified a question of law to the Supreme Court as a question of great public importance. The Supreme Court answered by holding that a defendant must raise a claim that conviction of a charged offense violates the statute of limitations in the trial court to preserve the issue for direct appeal. View "State v. Smith" on Justia Law

The Supreme Court affirmed the trial court’s order summarily denying Appellant’s renewed motion for a determination of intellectual disability as a bar to execution, filed under Fla. R. Crim. P. 3.203 and Fla. Stat. 921.137, holding that Appellant could not have met his burden to demonstrate that he was intellectually disabled.Appellant pleaded guilty to first-degree felony murder and was sentenced to death. In 2015, in the wake of Hall v. Florida, 134 S. Ct. 1986 (2014), Appellant filed a renewed motion for a determination of intellectual disability as a bar to execution. After a hearing, the trial court concluded that Appellant failed to prove that he was intellectually disabled because none of the three IQ scores he had presented fell within the standard error of measurement of IQ tests. The Supreme Court affirmed, holding that because Appellant failed to meet the significantly subaverage intellectual functioning prong of he intellectual disability standard, he was not entitled to relief. View "Quince v. State" on Justia Law

The Supreme Court affirmed the trial court’s order summarily denying Appellant’s renewed motion for a determination of intellectual disability as a bar to execution, filed under Fla. R. Crim. P. 3.203 and Fla. Stat. 921.137, holding that Appellant could not have met his burden to demonstrate that he was intellectually disabled.Appellant pleaded guilty to first-degree felony murder and was sentenced to death. In 2015, in the wake of Hall v. Florida, 134 S. Ct. 1986 (2014), Appellant filed a renewed motion for a determination of intellectual disability as a bar to execution. After a hearing, the trial court concluded that Appellant failed to prove that he was intellectually disabled because none of the three IQ scores he had presented fell within the standard error of measurement of IQ tests. The Supreme Court affirmed, holding that because Appellant failed to meet the significantly subaverage intellectual functioning prong of he intellectual disability standard, he was not entitled to relief. View "Quince v. State" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellant’s motion to vacate sentences of death under Fla. R. Crim. P. 3.851. The jury in Appellant’s case unanimously recommended death. In this successive postconviction motion, Appellant argued that his death sentences violated the Sixth Amendment in light of Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), and Hurst v. Florida, 136 S. Ct. 616 (2016) and that his death sentences violated the Eighth Amendment under Caldwell v. Mississippi, 472 U.S. 320 (1985), and must be vacated in light of Hurst, Hurst v. Florida, and Perry v. State, 210 So. 3d 630 (Fla. 2016). The circuit court denied relief. The Supreme Court affirmed, holding (1) the Hurst error in this case was harmless beyond a reasonable doubt; (2) Hurst-induced Caldwell claims against the standard jury instruction do not provide an avenue for Hurst relief; and (3) the circuit court properly denied Appellant’s Eighth Amendment Caldwell claim. View "Reynolds v. State" on Justia Law