Justia Criminal Law Opinion Summaries

The Supreme Court held that Petitioner had abused the Court's limited resources and will continue to burden the Court's resources if no action is taken and that the habeas petition filed in this case was a frivolous proceeding brought before the Court by a state prisoner, thus sanctioning Petitioner.In this case before the Court on Petitioner's petition for a writ of habeas corpus, the Supreme Court dismissed the petition as unauthorized and held that Petitioner failed to show cause why sanctions should not be imposed. Therefore, the Supreme Court directed the Clerk of 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. View "Stewart v. Dixon" on Justia Law

The Supreme Court held that the first element of Florida's assault statute, Fla. Stat. 784.011(1), requires not just the general intent to volitionally take the action of threatening to do violence but also that the actor direct the threat at a target, namely, another individual.Appellant was convicted in a federal district court of possession of a firearm by a convicted felon and sentenced to enhanced penalties under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). Appellant later filed a collateral challenge to his enhanced sentence under 28 U.S.C. 2255, challenging the district court's determination that his 1998 Florida conviction for aggravated assault with a deadly weapon under Fla. Stat. 784.021(1) qualified as a "violent felony" under the ACCA. The district court denied the motion. On appeal, the Eleventh Circuit Court of Appeal certified questions of Florida law to the Supreme Court. The 17-Nov Court answered the question in the affirmative, holding that section 784.011(1) requires that the actor "direct his action at[] or target[ing] another individual." View "Somers v. United States" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and his corresponding death sentence, as well as Defendant's conviction for conspiracy to commit murder, holding that Defendant was not entitled to relief on any of his allegations of error.On appeal, Defendant raised numerous challenges to his convictions and death sentences. The Supreme Court affirmed the judgment in its entirety, holding (1) there was no merit to Defendant's arguments regarding the guilt phase of his trial; and (2) Defendant's claims regarding the penalty phase of his trial were also without merit. View "Sievers v. State" on Justia Law

The Supreme Court approved the decision of the Second District Court of Appeal finding that an order granting Defendant's Fla. R. Crim. P. 3.800(a) motion and determining that Defendant's sentence was illegal was not a final order but remained subject to reconsideration until a final order imposing a corrected sentence was entered, holding that the Second District reached the correct conclusion.Defendant was convicted of a second-degree murder he committed when he was a juvenile and sentenced to life in prison with the possibility of parole after twenty-five years. In 2016, Defendant filed a Rule 3.800(a) motion asserting that his sentence was an illegal sentence. The trial court granted the motion and ordered a resentencing hearing. By the time the hearing took place in 2018, State v. Michel, 257 So. 3d 3, 4 (Fla. 2018), issued, holding that juvenile offenders' sentences of life with the possibility of parole after twenty-five years do not violate the Eighth Amendment. Consequently, the trial court vacated its prior order granting the Rule 3.800(a) motion and denied the motion. The Second District affirmed. The Supreme Court affirmed, holding that, based on a change in governing law, the trial court properly reconsidered its initial nonfinal order granting Defendant's Rule 3.800(a) motion. View "Morgan v. State" on Justia Law

The Supreme Court quashed the decision of the Fifth District Court of Appeal to grant a writ of certiorari in this case, holding that the district court did not have certiorari jurisdiction.Defendant was charged with two offenses, after which the State obtained a search warrant to search Defendant's smartphone, which was passcode protected. The trial court granted the State's motion to compel Defendant to disclose the smartphone's passcode, overruling Defendan't objection that such compelled disclosure would violate his privilege against self-incrimination under the Fifth Amendment. The Fifth District granted Defendant's petition for a writ of certiorari contesting the order to compel. The Supreme Court quashed the decision below, holding that because the order before the district court did not cause Defendant irreparable harm the district court did not have certiorari jurisdiction. View "State v. Garcia" on Justia Law

The Supreme Court approved of the decision of the First District Court of Appeal affirming Defendant's conviction for sexual battery in violation of Fla. Stat. 794.011(5)(b), holding that subsection 5(b) is not facially unconstitutional because it does not remove the State's burden to prove the defendant's general intent to engage in the act that constitutes the offense under the statute.On appeal, Defendant argued that subsection 5(b) was facially unconstitutional or must be read to include a requirement that the State prove that a criminal defendant knew or should have known the victim did not consent to sexual intercourse. The First District affirmed, disagreeing with Defendant that section 794.011(5)(b) was unconstitutional because it does not require the State to prove a defendant's mens rea. The Supreme Court affirmed, holding that the Legislature's reach did not approach the extent of its constitutional grasp where the statute makes sexual battery a crime of general intent not a strict liability offense. View "Statler v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Quentin Marcus Truehill's postconviction motion filed pursuant to Fla. R. Crim. P. 3.851 and denied Truehill's petition for a writ of habeas corpus, holding that Truehill was not entitled to relief.After a jury trial, Truehill was found guilty of first-degree murder and kidnapping. The jury unanimously recommended that true hill be sentenced to death. Truehill timely filed a motion for postconviction relief, which the circuit court denied in its entirety. Truehill appealed and filed a petition for habeas relief. The Supreme Court denied relief, holding (1) the postconviction court did not err in denying Truehill's postconviction claims; and (2) neither of the claims raised in Truehill's petition for a writ of habeas corpus had merit. View "Truehill v. State" on Justia Law

The Supreme Court held that John F. Mosley, who was resentenced to death for the murder of his ten-month-old son after a second penalty phase trial, was entitled to a new Spencer hearing and sentencing hearing but was not entitled to a new trial.Mosley was convicted of two counts of first-degree murder and was sentenced to death. When Mosley sought postconviction relief, the Supreme Court decided that a new penalty phase was required under Hurst v. Florida, 577 U.S. 466 (2016). After a second penalty phase trial, the jury found that the aggravating factors were sufficient to impose the death penalty. Mosley filed a motion for a new penalty phase trial. Before the ensuing Spencer hearing, Mosley filed a motion to represent himself pro se. The trial court failed to address Mosley's motion and appointed a public defender as Mosley's appellate counsel. The Supreme Court vacated Mosley's death sentence and remanded for a new sentencing hearing, holding that the trial court abused its discretion by failing to address Mosley's motion to represent himself at his Spencer hearing. View "Mosley v. State" on Justia Law

The Supreme Court quashed the decision of the court of appeal determining that Appellant's motion for disqualification was legally sufficient but that the trial judge's failure to grant the motion did not require reversal of Appellant's judgments and sentences, holding that there was a reasonable possibility that the trial judge's failure to grant the motion to disqualify contributed to Appellant's conviction.At issue before the Supreme Court was what harmless error test, if any, an appellate court should apply when a defendant in a criminal case asserts in an appeal from a judgment and sentence that the trial court erred in denying his legally sufficient motion to disqualify the trial judge for alleged bias or prejudice. The Supreme Court held (1) the proper test is set forth in State v. DiGuilio, 491 So. 2d 1129 (Fla. 1986); and (2) the court of appeal in this case correctly applied the harmless error standard, but applying the test laid out in DiGuilio, it could not be said that there was no reasonable probability that the error affected the verdict. View "Davis v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions and sentences of death for the first-degree murders of Patricia Moran and Deborah Royal, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant raised several issues, two of which the Supreme Court decided merited individualized attention. The Court then affirmed, holding (1) Defendant's argument that the State was impermissibly motivated by race when it struck venireperson Kimberly James from the jury and that its proffered reasons for the strike were pretextual was improperly preserved; (2) competent, substantial evidence supported the jury's verdict finding Defendant guilty of two counts of attempted first-degree murder with a vehicle; and (3) Defendant's remaining allegations of error were without merit. View "Gordon v. State" on Justia Law