Justia Criminal Law Opinion Summaries

A petition for a writ of habeas corpus is the proper vehicle by which to seek release from close management, which the Florida Administrative Code defines as “the confinement of an inmate apart from the general population.”Defendant, an inmate, was reassigned to a “close management” cousin classification. The Department of Corrections upheld the decision. Defendant then filed a petition for a writ of habeas corpus, which the circuit court denied. On appeal, the First District Court of Appeal announced its decision to “recede from prior decisions…allow[ing] [c]lose [m]anagement decisions to be challenged by writ of habeas corpus,” concluding that the appropriate vehicle for challenges to close management assignments was a petition for writ of mandamus. The Supreme Court quashed the decision of the First District, holding that a petition for a writ of habeas corpus remains the correct mechanism by which to challenge a reassignment. View "Banks v. Jones" on Justia Law

Defendant was entitled to a new penalty phase proceeding pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016) and Mosley v. State, 209 So. 3d 1248 (Fla. 2016) and based on his claim of ineffective assistance of penalty phase counsel.Defendant was convicted of first-degree murder and other crimes. The jury recommended a sentence of death for the murder by a vote of eleven to one. The trial court imposed a sentence of death. Defendant later filed a motion to vacate judgment of conviction and sentence pursuant to Fla. R. Crim. P. 3.851. The postconvcition denied all claims, concluding that penalty phase counsel was deficient but that Defendant was not prejudiced as a result. Defendant appealed and filed a petition for writ of habeas corpus seeking relief pursuant to Hurst v. Florida, 577 U.S. __ (2016). The Supreme Court affirmed the denial of postconvcition relief but granted the petition for writ of habeas corpus, vacated Defendant’s death sentence, and remanded, holding (1) trial counsel was deficient for failing to discover paternal neglect, paternal abuse, and the extent of paternal substance abuse, and the deficiency was prejudicial; and (2) the failure to require a unanimous verdict regarding the sentence of death was not harmless. View "Ellerbee v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions for first-degree murder and other crimes but vacated his death sentence and remanded for a new penalty phase. After the penalty phase, the jury voted nine to three to recommend a sentence of death. The trial judge followed the jury’s recommendation. On appeal, Defendant raised seven allegations of error regarding guilt phase issues. The Supreme Court held that none of the issues warranted relief and that the evidence was sufficient to support Defendant’s first-degree murder conviction. The court, however, concluded that Defendant’s death sentence violated Hurst v. Florida, 577 U.S. __ (2016) and that the error in Defendant’s sentencing was not harmless beyond a reasonable doubt. View "Lebron 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. Appellant was convicted of two counts of first-degree premeditated murder. Following a penalty phase bench trial and a Spencer hearing, the trial court sentenced Appellant to death for each of the murders. This appeal concerned the denial of Appellant’s first successive postconviction motion in which Appellant raised several 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 affirmed, holding that Appellant validly waived the right to a penalty phase jury, and Appellant’s arguments did not compel departing from precedent denying Hurst relief to defendants that have waived the right to a penalty phase jury. View "Allred v. State" on Justia Law

In this appeal from an order entered on Defendant’s postconviction motion to vacate his conviction of first-degree murder and sentence of death and related convictions and sentences, the Supreme Court reversed the portion of the postconviction court’s order granting Defendant a new guilt phase but affirmed the portions of the postconviction court’s order granting Defendant a new penalty phase. The court held that the postconviction court (1) erred in granting relief on Defendant’s ineffective assistance of counsel claims regarding the voluntariness and reliability of Defendant’s written statement to the police detailing his involvement in the victim’s death and trial counsel’s guilt phase investigation; and (2) did not err in finding that trial counsel was ineffective for failing adequately to investigate and prepare for the penalty phase. As to Defendant’s cross-appeal, the Supreme Court held that the postconviction court (1) did not err to the extent that it denied four of Defendant’s postconviction claims; and (2) did not err in declining to conduct a cumulative error analysis. View "State v. Morrison" on Justia Law

The Supreme Court affirmed the circuit court’s summary denial of Appellant’s successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851. In his motion, Appellant, a prisoner under sentence of death, raised five claims of newly discovered evidence or Brady violations. The court held (1) all of Appellant’s claims were properly denied by the trial court; and (2) where the only additional evidence presented in this proceeding potentially admissible in any retrial was that regarding evidence addressed in claim two, and there was no reasonable probability that, had this evidence been disclosed to the defense, the result of the trial would have been different, Appellant was not entitled to a new trial when all of the allegations presented in this proceeding were considered cumulatively. View "Suggs v. State" on Justia Law

The Supreme Court in this case struck certain unconstitutional language from the 2013 amendments to Fla. Stat. 766.106 and 766.1065, which authorized secret, ex parte interviews to the list of informal discovery devices to which a medical malpractice claimant seeking redress must consent, holding (1) the right to privacy in the Florida Constitution attaches during the life of a citizen and is not retroactively destroyed by death, and this constitutional protection shields irrelevant, protected medical history and other private information from the medical malpractice litigation process; (2) in the wrongful death context, standing in the position of the decedent, the administrator of the decedent’s estate has standing to assert the decedent’s privacy rights; and (3) the Legislature unconstitutionally conditioned a plaintiff’s right of access to courts for redress of injuries caused by medical malpractice, whether in the wrongful death or personal injury context, on the claimant’s waiver of the constitutional right to privacy. View "Weaver v. Myers" on Justia Law

The good-faith exception to the exclusionary rule did not apply to law enforcement officers’ warrantless search of Petitioner’s cell phone in this case.Petitioner was charged with one count of traveling to meet a minor to commit an unlawful sex act, one count of soliciting a minor to commit an unlawful sex act, and three counts of transmission of material harmful to a minor. At the time of Petitioner’s arrest, the arresting officers conducted a search incident to arrest and seized his cell phone. Petitioner filed a motion to suppress the evidence found on his cell phone, arguing that the warrantless search violated his Fourth Amendment rights. The trial court granted the motion to suppress, relying on the holding in Smallwood v. State (Smallwood II), 113 So. 3d 724 (Fla. 2013), that warrantless cell phone searches are unconstitutional. The First District Court of Appeal reversed, concluding that because the officers were relying in good faith on the holding in Smallwood v. State (Smallwood I), 61 So. 3d 448 (Fla. 1st DCA 2011), the good-faith exception to the exclusionary rule applied. The Supreme Court reversed, holding that, under Davis v. United States, 564 U.S. 229(2011), the good-faith exception did not apply in this case. View "Carpenter v. State" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellant’s third and fourth successive motions for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851 and denied Appellant’s motions for stay of execution. The Supreme Court held (1) the circuit court properly denied Appellant’s challenge to the constitutionality of the lethal injection protocol; (2) the circuit court properly denied Appellant’s challenges to the power of the Governor to sign death warrants; (3) the circuit court properly found that Appellant’s claim that his sentence was disproportionate was procedurally barred; (4) the circuit court properly sustained the State’s objections to disclosure of certain records; and (5) the circuit court properly rejected Appellant’s various Hurst challenges. View "Hannon v. State" on Justia Law

The Supreme Court granted Petitioner’s petition for a writ of habeas corpus, vacated his sentence of death, and remanded the case to the circuit court for a new penalty phase. Petitioner’s death sentence, which his penalty phase jury recommended by a vote of ten to two, became final in 2004. Petitioner petitioned the Supreme Court for a writ of habeas corpus seeking relief under Hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court held (1) Hurst applies retroactively to Petitioner; and (2) Petitioner’s death sentence violates Hurst, and the error is not harmless beyond a reasonable doubt. View "Taylor v. Jones" on Justia Law