Justia Criminal Law Opinion Summaries

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

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