Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the order of the circuit court summarily denying Appellant’s motion to vacate a judgment of conviction of first-degree murder and a sentence of death filed under Fla. R. Crim. P. 3.851. In his successive postconviction motion, Appellant, who was convicted of four counts of first-degree murder with a firearm, sought relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). In its answer, the State asserted that the motion should be summarily denied because Appellant waived his rights to Hurst relief when he waived his penalty phase jury. The circuit court summarily denied the motion. The Supreme Court affirmed, holding that Appellant was not entitled to postconviction relief in light of this Court’s decisions in Brant v. State, 197 So. 3d 1051 (Fla. 2016), and Mullens v. State, 197 So. 3d 16 (Fla. 2016). View "Hutchinson v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant’s motion to vacate a judgment of conviction of first-degree murder and a sentence of death filed under Fla. R. Crim. P. 3.851. In his successive postconviction motion, Appellant, who was convicted of four counts of first-degree murder with a firearm, sought relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). In its answer, the State asserted that the motion should be summarily denied because Appellant waived his rights to Hurst relief when he waived his penalty phase jury. The circuit court summarily denied the motion. The Supreme Court affirmed, holding that Appellant was not entitled to postconviction relief in light of this Court’s decisions in Brant v. State, 197 So. 3d 1051 (Fla. 2016), and Mullens v. State, 197 So. 3d 16 (Fla. 2016). View "Hutchinson v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions for murder and kidnapping but vacated his sentence of death and remanded for the imposition of a life sentence without eligibility for parole based on Defendant’s performance of his part of his agreement with the State. In the agreement, the State agreed not to seek the death penalty if Defendant agreed to lead investigators to the body. After the body was discovered, the State filed its notice of intent to seek the death penalty. The trial court subsequently denied Defendant’s motion to enforce the agreement. On appeal, Defendant argued that the trial court erred in denying his motion to prohibit the State from seeking the death penalty. The Supreme Court agreed, holding that once Defendant performed his end of the bargain with the State, the State was obligated to uphold its end of the agreement. As to Defendant’s remaining arguments concerning his conviction, the Supreme Court denied relief. The Supreme Court remanded the case with instructions for the trial court to reduce Defendant’s death sentence to life imprisonment without the possibility of parole. View "Johnson v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions for murder and kidnapping but vacated his sentence of death and remanded for the imposition of a life sentence without eligibility for parole based on Defendant’s performance of his part of his agreement with the State. In the agreement, the State agreed not to seek the death penalty if Defendant agreed to lead investigators to the body. After the body was discovered, the State filed its notice of intent to seek the death penalty. The trial court subsequently denied Defendant’s motion to enforce the agreement. On appeal, Defendant argued that the trial court erred in denying his motion to prohibit the State from seeking the death penalty. The Supreme Court agreed, holding that once Defendant performed his end of the bargain with the State, the State was obligated to uphold its end of the agreement. As to Defendant’s remaining arguments concerning his conviction, the Supreme Court denied relief. The Supreme Court remanded the case with instructions for the trial court to reduce Defendant’s death sentence to life imprisonment without the possibility of parole. View "Johnson v. State" on Justia Law

The Supreme Court found that Petitioner failed to show cause why he should not be barred from filing further pro se filings in this court and directed the clerk of the court to reject any 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.In 2006, Petitioner was convicted of several criminal offenses and sentenced to thirty years’ imprisonment. The court of appeal affirmed. Since then, Petitioner demonstrated a pattern of vexatious filing of meritless pro se requests for relief in the Supreme Court. The Supreme Court dismissed the instant petition for writ of habeas corpus filed in 2017 as unauthorized pursuant to Baker v. State, 878 So. 2d 1236 (Fla. 2004), and expressly retained jurisdiction to consider the imposition of sanctions. The court subsequently determined that Petitioner had abused this court’s limited judicial resources, sanctioned Petitioner, and found the petition filed in this case was a frivolous proceeding filed by a state prisoner. View "Hickmon v. Jones" on Justia Law

The Supreme Court found that Petitioner failed to show cause why he should not be barred from filing further pro se filings in this court and directed the clerk of the court to reject any 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.In 2006, Petitioner was convicted of several criminal offenses and sentenced to thirty years’ imprisonment. The court of appeal affirmed. Since then, Petitioner demonstrated a pattern of vexatious filing of meritless pro se requests for relief in the Supreme Court. The Supreme Court dismissed the instant petition for writ of habeas corpus filed in 2017 as unauthorized pursuant to Baker v. State, 878 So. 2d 1236 (Fla. 2004), and expressly retained jurisdiction to consider the imposition of sanctions. The court subsequently determined that Petitioner had abused this court’s limited judicial resources, sanctioned Petitioner, and found the petition filed in this case was a frivolous proceeding filed by a state prisoner. View "Hickmon v. Jones" on Justia Law

The Supreme Court affirmed the trial court’s denial of Appellant’s third successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851, holding that the trial court’s failure to hold a case status conference was harmless error and that no evidentiary hearing was required because the motion was legally insufficient on its face and refuted by the record. Further, the trial court did not err by summarily denying Appellant’s claim based on newly discovered evidence and Brady v. Maryland, 373 U.S. 83 (1963). View "Sochor v. State" on Justia Law

The Supreme Court affirmed the trial court’s denial of Appellant’s third successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851, holding that the trial court’s failure to hold a case status conference was harmless error and that no evidentiary hearing was required because the motion was legally insufficient on its face and refuted by the record. Further, the trial court did not err by summarily denying Appellant’s claim based on newly discovered evidence and Brady v. Maryland, 373 U.S. 83 (1963). View "Sochor v. State" on Justia Law

The Supreme Court quashed the decision of the First District Court of Appeal in Roberts v. State, 168 So. 3d 252 (Fla. 1st DCA 2015), to the extent it was inconsistent with the Supreme Court’s decision in Walton v. State, 208 So. 3d 60 (Fla. 2016), holding that Defendant was entitled to a new trial pursuant to Walton.A jury found Defendant guilty of attempted second-degree murder and other offenses. On appeal, Defendant argued that the trial court fundamentally erred by failing to instruct the jury on the necessarily lesser included offense of attempted manslaughter by act. The First District rejected Defendant’s claims and affirmed her convictions and sentences. The Supreme Court quashed the decision below, holding that, like Walton, the trial court’s failure to give the attempted manslaughter by act instruction constituted fundamental error. The court remanded the case to the First District for further proceedings. View "Roberts v. State" on Justia Law

The Supreme Court quashed the decision of the First District Court of Appeal in Roberts v. State, 168 So. 3d 252 (Fla. 1st DCA 2015), to the extent it was inconsistent with the Supreme Court’s decision in Walton v. State, 208 So. 3d 60 (Fla. 2016), holding that Defendant was entitled to a new trial pursuant to Walton.A jury found Defendant guilty of attempted second-degree murder and other offenses. On appeal, Defendant argued that the trial court fundamentally erred by failing to instruct the jury on the necessarily lesser included offense of attempted manslaughter by act. The First District rejected Defendant’s claims and affirmed her convictions and sentences. The Supreme Court quashed the decision below, holding that, like Walton, the trial court’s failure to give the attempted manslaughter by act instruction constituted fundamental error. The court remanded the case to the First District for further proceedings. View "Roberts v. State" on Justia Law