Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the circuit court’s order denying Eric Scott Branch’s motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Branch 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). Branch was sentenced to death following a jury’s recommendation for death by a vote of ten to two. Branch’s sentence of death became final in 1997. The Supreme Court held that Hurst did not apply retroactively to Branch’s sentence of death and thus affirmed the denial of Branch’s motion. View "Branch v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Donald Bradley’s petition for a writ of habeas corpus, holding that Bradley 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). Bradley was sentenced to death following a jury’s recommendation for death by a vote of ten to two. Bradley’s sentence of death became final in 2001. The Supreme Court held that Hurst did not apply retroactively to Bradley’s sentence of death and thus affirmed the denial of Bradley’s motion. View "Bradley v. Jones" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Kayle Barrington Bates’ motion filed pursuant to Fla. R. Crim. P. 3.851 and denied his petition for a writ of habeas corpus, holding that Bates 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). Bates was sentenced to death following a jury’s recommendation for death by a vote of nine to three. Bates’ sentence became final in 2000. The Supreme Court held that Hurst did not apply retroactively to Bates' sentence of death. View "Bates v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Pressley Bernard Alston’s motion filed pursuant to Fla. R. Crim. P. 3.851 and denied his petition for a writ of habeas corpus, holding that Alston 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). Alston was sentenced to death following a jury’s recommendation for death by a vote of nine to three. Alston’s sentence became final in 1999. The Supreme Court held that Hurst did not apply retroactively to Alston’s sentence of death. View "Alston v. State" on Justia Law

The Supreme Court affirmed the trial court’s order summarily denying Appellant’s successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851.Appellant pleaded guilty to first-degree murder and burglary of a dwelling and was sentenced to death. At issue on this appeal was Appellant’s successive motion for postconviction relief in which Appellant argued he was entitled to relief under Hurst v. Florida, 136 S. Ct. 616 (2016). The trial court denied relief, concluding that Appellant was not entitled to relief based on the court’s decisions in Asay v. State, 210 So. 3d 1, 22 (Fla. 2016) and Mullens v. State, 197 So. 3d 16, 14 (Fla. 2016). The Supreme Court affirmed, holding (1) because Appellant waived his right to a penalty phase jury, he was not entitled to Hurst relief; and (2) because Appellant’s sentence became final nearly twenty years before Ring v. Arizona, 536 U.S. 584 (2002), was decided, his Hurst claim was also foreclosed by Asay. View "Quince v. State" on Justia Law

The Supreme Court affirmed the trial court’s order summarily denying Appellant’s renewed motion for a determination of intellectual disability as a bar to execution filed under Fla. R. Crim. P. 3.203 and Fla. Stat. 921.137.Appellant pleaded guilty to first-degree murder and burglary of a dwelling and was sentenced to death. Appellant filed a successive motion for postconviction relief seeking to vacate his death sentence on the ground that he was intellectually disabled and therefore ineligible for the death penalty. The trial court denied the motion. After the United States Supreme Court issued its decision in Hall v. Florida, 572 U.S. __ (2014), Appellant filed a renewed motion for a determination of intellectual disability as a bar to execution. The trial court concluded that Appellant failed to prove that he was intellectually disabled. The Supreme Court affirmed, holding that Appellant was not entitled to relief on any of his claims. View "Quince v. State" on Justia Law

The Supreme Court approved the First District Court of Appeal’s holding in Hall v. Lopez, 213 So. 3d 1003 (Fla. 1st DCA 2017), that Fla. Stat. 57.105 does not prohibit awarding attorney’s fees in dating, repeat, and sexual violence injunction proceedings under Fla. Stat. 784.046.Nicole Lopez filed a petition for injunction for protection against repeat and dating violence under section 784.046 against Sean Hall and received a temporary injunction. Hall later moved for attorney’s fees and sanctions under section 57.105, claiming that Lopez perjured herself in her petitions. Thereafter, Lopez voluntarily dismissed her action. The trial court denied Hall’s motion for attorney’s fees, concluding that section 784.046 does not authorize an award of section 57.105 attorney’s fees on any basis. The First District reversed. The Supreme Court affirmed, holding that section 57.105 may be applied to repeat, dating, and sexual violence injunction proceedings under section 784.046. View "Lopez v. Hall" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree murder but vacated his death sentence and remanded for a new penalty phase. Defendant was sentenced to death after a jury recommended the death penalty by a vote of ten to two. On appeal, the Supreme Court held (1) the trial court did not err by allowing Defendant’s co-defendant to testify that he and Defendant were involved in the separate murder; (2) substantial evidence supported the conviction; but (3) the jury’s nonunanimous recommendation of death violated Hurst v. State, 202 So. 3d 40 (Fla. 2016), and the error was not harmless beyond a reasonable doubt. View "Kirkman v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of first-degree murder but vacated his sentence of death and remanded for a new penalty phase. The jury in this case recommended death by a vote of ten to two. The Supreme Court held (1) the trial court did not err when it granted the State’s motion for reconsideration of Defendant’s motion for change of venue; (2) the trial court did not err in overruling Defendant’s objection to the admission of his spontaneous statements while under observation in jail; (3) assuming that two of the prosecutor’s statements were improper, neither of these issues individually amounted to fundamental error, and the cumulative effect of these errors did not deprive Defendant of a fair trial; (4) substantial evidence supported Defendant’s conviction; but (5) the Hurst error in Defendant’s sentencing was not harmless beyond a reasonable doubt. View "Morris v. State" on Justia Law

The Supreme Court approved the First District Court of Appeal’s decision ruling that the Dangerous Sexual Felony Offender Act (the DSFO Act) authorizes a mandatory minimum life sentence regardless of the statutory maximum for the crimes.The First District certified conflict with Wilkerson v. State, 143 So. 3d 462 (Fla. 5th DCA 2014), in which the First District Court of Appeal concluded that, when the statutory maximum for a particular crimes is less than twenty-five years, the DSFO authorizes a trial court to impose only a mandatory minimum term of twenty-five years’ imprisonment. In the instant case, the trial court sentenced Defendant under the DSFO Act to a mandatory minimum life sentence for a second-degree felony that generally carried a fifteen-year statutory maximum. The Supreme Court approved the First District’s decision in Williams and disapproved the Fifth District’s decision in Wilkerson to the extent it was inconsistent with this opinion, holding that, in upholding the sentence int his case, the First District interpreted the “25 to life” provision in the DSFO Act consistently with Mendenhall v. State, 48 So, 3d 740 (Fla. 2010), which controls this case. View "Williams v. State" on Justia Law