Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the order of the postconviction court denying Appellant’s successive motion for postconviction relief seeking relief based on Hurst v. Florida, 136 S. Ct. 616 (2016), Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016), and Perry v. State, 210 So. 3d 630 (Fla. 2016).Appellant was convicted of first-degree murder and kidnapping with intent to commit or facilitate the commission of a homicide. The jury unanimously recommended death. On direct appeal, the Supreme Court affirmed Appellant’s first-degree murder conviction but reversed the judgment of guilt of kidnapping and remanded for entry of judgment for false imprisonment. Appellant’s sentence of death became final in 2005. On appeal from the denial of his postconviction motion, Appellant argued that the Hurst error in his case was not harmless beyond a reasonable doubt even where the jury unanimously recommended death. The Supreme Court disagreed, holding that the Hurst error in Appellant’s case was harmless beyond a reasonable doubt. View "Crain v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Appellant’s successive postconviction motion to vacate a sentence of death under Fla. R. Crim. P. 3.851. In his successive motion, Appellant claimed that his death sentence 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 violated the Eighth Amendment under Caldwell v. Mississippi, 472 U.S. 320 (1985). The Supreme Court affirmed the circuit court’s order summarily denying Appellant’s successive motion for postconviction relief, holding (1) any Hurst error in this case was harmless beyond a reasonable doubt; and (2) Appellant’s Caldwell claim was procedurally barred because it was raised and rejected on direct appeal. View "Taylor v. State" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Appellant’s successive postconviction motion to vacate a sentence of death under Fla. R. Crim. P. 3.851. In his successive motion, Appellant claimed that his death sentence 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 violated the Eighth Amendment under Caldwell v. Mississippi, 472 U.S. 320 (1985). The Supreme Court affirmed the circuit court’s order summarily denying Appellant’s successive motion for postconviction relief, holding (1) any Hurst error in this case was harmless beyond a reasonable doubt; and (2) Appellant’s Caldwell claim was procedurally barred because it was raised and rejected on direct appeal. View "Taylor v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order summarily denying Defendant’s first successive motion for postconviction relief, holding that any Hurst error in this case was harmless beyond a reasonable doubt.In 1998, a jury convicted Defendant of two counts of first-degree murder. The jury unanimously recommended the death sentence for each murder by a vote of twelve to zero. The Supreme Court affirmed the convictions and death sentences on direct appeal. In 2017, Defendant filed his first successive postconviction motion in which he raised numerous claims in light of Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court summarily denied Defendant’s successive postconviction motion. The Supreme Court affirmed, holding that any Hurst error was harmless. View "Smithers v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order summarily denying Defendant’s first successive motion for postconviction relief, holding that any Hurst error in this case was harmless beyond a reasonable doubt.In 1998, a jury convicted Defendant of two counts of first-degree murder. The jury unanimously recommended the death sentence for each murder by a vote of twelve to zero. The Supreme Court affirmed the convictions and death sentences on direct appeal. In 2017, Defendant filed his first successive postconviction motion in which he raised numerous claims in light of Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court summarily denied Defendant’s successive postconviction motion. The Supreme Court affirmed, holding that any Hurst error was harmless. View "Smithers v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order summarily denying Appellant’s first successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that any Hurst error in this case was harmless beyond a reasonable doubt.In 2000, a jury convicted Appellant of first-degree murder and sexual battery upon a person twelve years of age or older with use of a deadly weapon. The jury unanimously recommended the death sentence by a vote of twelve to zero. The Supreme Court affirmed Appellant’s convictions and death sentence on direct appeal. In 2016, Appellant filed his first successive postconviction motion arguing that he was entitled to relief based on Hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). The circuit court summarily denied Appellant’s successive postconviction motion. The Supreme Court affirmed, holding that any Hurst error in this case was harmless beyond a reasonable doubt. View "Grim v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order summarily denying Appellant’s first successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that any Hurst error in this case was harmless beyond a reasonable doubt.In 2000, a jury convicted Appellant of first-degree murder and sexual battery upon a person twelve years of age or older with use of a deadly weapon. The jury unanimously recommended the death sentence by a vote of twelve to zero. The Supreme Court affirmed Appellant’s convictions and death sentence on direct appeal. In 2016, Appellant filed his first successive postconviction motion arguing that he was entitled to relief based on Hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). The circuit court summarily denied Appellant’s successive postconviction motion. The Supreme Court affirmed, holding that any Hurst error in this case was harmless beyond a reasonable doubt. View "Grim v. State" on Justia Law

The Supreme Court affirmed the orders of the circuit court denying Ronnie Johnson’s motions filed under Fla. R. Crim. P. 3.851 seeking 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). Johnson was sentenced to death for one murder conviction following a jury’s recommendation for death by a vote of seven to five. Johnson was also sentenced to death for a second murder following a jury’s recommendation for death by a vote of nine to three. Both of Johnson’s death sentences became final in 1998. In affirming the denial of Johnson’s motions, the Supreme Court held that Hurst did not apply retroactively to Johnson’s sentences of death. View "Johnson v. State" on Justia Law

The Supreme Court affirmed the orders of the circuit court denying Ronnie Johnson’s motions filed under Fla. R. Crim. P. 3.851 seeking 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). Johnson was sentenced to death for one murder conviction following a jury’s recommendation for death by a vote of seven to five. Johnson was also sentenced to death for a second murder following a jury’s recommendation for death by a vote of nine to three. Both of Johnson’s death sentences became final in 1998. In affirming the denial of Johnson’s motions, the Supreme Court held that Hurst did not apply retroactively to Johnson’s sentences of death. View "Johnson v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Appellant’s motion filed under 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 sentenced to death following a jury’s recommendation for death by a vote of eight to four, and his sentence of death became final in 2001. In affirming, the Supreme Court held that Hurst did not apply retroactively to Appellant’s sentence of death and, accordingly, affirmed the denial of Appellant’s motion. View "Gonzalez v. State" on Justia Law