Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the postconviction court’s summary denial of Appellant’s postconviction motion to vacate his sentence of death under Fla. R. Crim. P. 3.851, holding that any Hurst error during Appellant’s penalty phase proceedings was harmless beyond a reasonable doubt.Appellant was convicted of attempted robbery and first-degree murder and sentenced to death. This appeal was from Appellant’s successive postconviction motion in which he claimed that his death sentence was unconstitutional under Hurst v. Florida, 136 S. Ct. 616 (2016) and that his death sentence violated the Eighth Amendment under Hurst v. Florida. The postconviction court denied the motion. The Supreme Court affirmed, holding that the postconviction court properly denied relief on Appellant’s claims. View "Franklin v. State" on Justia Law

The Supreme Court affirmed the circuit court’s orders denying Appellant’s successive motion for postconviction relief, filed under Fla. R. Crim. P. 3.851, and denying his demands for additional public records, filed under Fla. R. Crim. P. 3.852. The court held (1) because Appellant’s successive motion was filed after the expiration of the relevant one-year time limitation and none of the exceptions to the one-year time limitation in Rule 3.851(d)(2) were applicable to the claims raised by Appellant in his successive postconviction motion, the postconviction court properly denied the successive motion as untimely; and (2) there was no abuse of discretion in the trial court’s denial of Appellant’s requests for additional public records. View "Hamilton v. State" on Justia Law

The Supreme Court affirmed the circuit court’s summary denial of Appellant’s postconviction motion filed pursuant to Fla. R. Crim. P. 3.851 seeking sentencing relief under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). Appellant, a prisoner under sentence of death who waived a penalty phase jury, argued that the waiver was not valid because he was incompetent at the time of the waiver. The circuit court summarily denied the motion. The Supreme Court affirmed, holding that the time for Appellant to contest the prior competency determination had passed. View "Rodgers v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Norberto Pietri’s motion filed under Fla. R. Crim. P. 3.851, holding that Pietri was not entitled to 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). Pietri was sentenced to death following a jury’s recommendation for death by a vote of eight to four. Pietri’s sentence of death became final in 1995. The Supreme Court held that Hurst did not apply retroactively to Pietri’s sentence of death and, accordingly, affirmed the denial of Pietri’s motion. View "Pietri v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Norberto Pietri’s motion filed under Fla. R. Crim. P. 3.851, holding that Pietri was not entitled to 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). Pietri was sentenced to death following a jury’s recommendation for death by a vote of eight to four. Pietri’s sentence of death became final in 1995. The Supreme Court held that Hurst did not apply retroactively to Pietri’s sentence of death and, accordingly, affirmed the denial of Pietri’s motion. View "Pietri v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Thomas M. Overton’s motion filed under Fla. R. Crim. P. 3.851, holding that Overton was not entitled to 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). Overton was convicted of two counts of murder. Overton was sentenced to death on both counts following a jury’s recommendation for death by a vote of nine to three on one count and a vote of eight to four on another count. Overton’s sentence of death became final in 2002. The Supreme Court held that Hurst did not apply retroactively to Overton’s sentence of death and, accordingly, affirmed the denial of Overton’s motion. View "Overton v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Thomas M. Overton’s motion filed under Fla. R. Crim. P. 3.851, holding that Overton was not entitled to 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). Overton was convicted of two counts of murder. Overton was sentenced to death on both counts following a jury’s recommendation for death by a vote of nine to three on one count and a vote of eight to four on another count. Overton’s sentence of death became final in 2002. The Supreme Court held that Hurst did not apply retroactively to Overton’s sentence of death and, accordingly, affirmed the denial of Overton’s motion. View "Overton v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Antonio Labaron Melton’s motion filed under Fla. R. Crim. P. 3.851, holding that Melton was not entitled to 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). Melton was sentenced to death following a jury’s recommendation for death by a vote of eight to four. Melton’s sentence of death became final in 1994. The Supreme Court held that Hurst did not apply retroactively to Melton’s sentence of death and, accordingly, affirmed the denial of Melton’s motion. View "Melton v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Antonio Labaron Melton’s motion filed under Fla. R. Crim. P. 3.851, holding that Melton was not entitled to 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). Melton was sentenced to death following a jury’s recommendation for death by a vote of eight to four. Melton’s sentence of death became final in 1994. The Supreme Court held that Hurst did not apply retroactively to Melton’s sentence of death and, accordingly, affirmed the denial of Melton’s motion. View "Melton v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Alvin Leroy Morton’s motion filed under Fla. R. Crim. P. 3.851, holding that Morton was not entitled to 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). Morton was convicted of two counts of first-degree murder and sentenced to death following a jury’s recommendation for death by a vote of eleven to one on both counts. Derrick’s sentence of death became final in 2001. The Supreme Court held that Hurst did not apply retroactively to Morton’s sentence of death and, accordingly, affirmed the denial of Morton’s motion. View "Morton v. State" on Justia Law