Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant’s conviction for first-degree murder but vacated his sentence of death and remanded for a new penalty phase. The court held (1) the evidence was sufficient to support Defendant’s conviction; (2) the trial court did not abuse its discretion in excluding evidence of the victim’s drug use; (3) the trial court did not abuse its discretion by not conducting an inquiry into counsel’s effectiveness pursuant to Nelson v. State, 274 So. 2d 256 (Fla. 4th DCA 1973); (4) Defendant’s claim of ineffective assistance of counsel was not cognizable on direct appeal; (5) competent, substantial evidence supported the trial court’s finding that Defendant was not intellectually disabled; but (6) in light of a ten-to-two jury recommendation for death, error pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016), occurred in this case, and the error was not harmless beyond a reasonable doubt. View "Glover v. State" on Justia Law

The Supreme Court denied the petition for a writ of quo warranto filed by Petitioner, the state attorney for Florida’s Ninth Judicial Circuit, challenging Governor Rick Scott’s authority to reassign the prosecution of death penalty eligible cases in the Ninth Circuit to the state attorney for Florida’s Fifth Judicial Circuit. The Governor reassigned the prosecution of death penalty eligible cases pending in the Ninth Circuit after Petitioner announced her intent to implement a blanket policy of not seeking the death penalty in any eligible case. The Supreme Court held that the Governor did not abuse his discretion in reassigning the cases at issue to the state attorney for Florida’s Fifth Judicial Circuit pursuant to Fla. Stat. 27.14. View "Ayala v. Scott" on Justia Law

Manslaughter is a category one lesser included offense of second-degree felony murder.The Fourth District Court of Appeal granted Defendant’s motion to certify to the Supreme Court the question of whether manslaughter is a necessarily lesser included offense of second-degree felony murder after Defendant appealed his conviction of second-degree felony murder and burglary. On appeal, Defendant argued that the trial court erred in denying his request for an instruction on manslaughter as a lesser included offense of second-degree felony murder. The Supreme Court answered the appellate court’s certified question in the affirmative, holding that manslaughter is a necessarily lesser included offense of second-degree felony murder. View "Dean v. State" on Justia Law

The Supreme Court reversed Defendant’s sentences of death imposed for his convictions of first-degree murder and remanded for a new penalty phase based on Hurst v. State, 202 So. 3d 40 (Fla. 2016) and Mosley v. State, 209 So. 3d 1248 (Fla. 2016), holding that the jury’s nonunanimous recommendation of death by a vote of seven to five as to both murders was not harmless beyond a reasonable doubt. The court thus reversed the postconviction court’s order denying postconviction relief as to the penalty phase of Defendant’s trial but affirmed the postconviction court’s order denying postconviction relief as to the guilt phase. The court also denied Defendant’s habeas petition to the extent he sought relief pursuant to Hurst and affirmed the postconviction court’s denial of Defendant’s successive motion to vacate judgment and sentence. View "Gregory v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions and death sentences for the first-degree murders of a mother and her two children. The court held (1) the trial court did not err in concluding that the “particularly vulnerable” aggravator was proven beyond a reasonable doubt as to the murders of the two children; (2) the trial court did not err in finding that the especially heinous, atrocious, or cruel aggravator applied to one of the children’s murder; (3) Defendant’s challenges to the sufficiency of the sentencing order were unavailing; (4) any error in the trial court’s failure to consider parole ineligibility as a mitigating circumstance was harmless beyond a reasonable doubt; (5) Defendant’s guilty pleas were knowingly, intelligently, and voluntarily entered; (6) the death sentences were proportionate; and (7) Defendant was not entitled to relief under Hurst v. Florida, 577 U.S. __ (2016). View "Covington v. State" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Mark Asay’s third successive motion for postconviction relief and denied Asay’s petition for a writ of habeas corpus. The court also denied Asay’s motion for a stay of execution and his application for a stay of execution. Asay, a prisoner under a sentence of death, alleged in his third petition for postconviction relief that he was denied access to public records, that the new lethal injection protocol was unconstitutional, that the manner in which the execution was reset violated due process, and that Fla. Stat. 922.06 is unconstitutional. The Supreme Court affirmed the circuit court’s denial of these claims, holding that Asay did not demonstrate that he was entitled to relief on his claims. Further, the court held that Asay did not present a basis for relief in his habeas claims attacking the constitutionality of his death sentences based on the nonunanimous verdicts because Asay did not present a novel claim for the court’s consideration. View "Asay v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order summarily denying Appellant’s successive postconviction motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851. Appellant, a prisoner whose death sentence became final in 2000, argued that the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and the Florida Supreme Court’s decision on remand in Hurst v. State, 202 So. 3d 40 (Fla. 2016), rendered his death sentence unconstitutional. The circuit court concluded that the Supreme Court’s decision in Asay v. State, 210 So. 3d 1 (Fla. 2016), precluded relief because Appellant’s death sentence was final when the United States Supreme Court decided Ring v. Arizona, 536 U.S. 584 (2002). The Supreme Court affirmed, holding that Appellant’s arguments did not compel departing from precedent. View "Hitchcock v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree murder, vacated his death sentence, and remanded for a new penalty phase, holding that there was sufficient evidence to support Defendant’s convictions but that, under Hurst v. State, 202 So. 3d 40 (Fla. 2016), Defendant was entitled to a new penalty phase.After a trial, the jury recommended the death penalty by a vote of ten to two for Defendant’s murder conviction. Upon weighing the aggravation and mitigation, the trial court sentenced Defendant to death. The Supreme Court held (1) competent, substantial evidence supported Defendant’s convictions under both premeditated murder and felony murder; (2) death was a proportionate punishment in this case; but (3) considering the nonunanimous jury recommendation and reasoning, there was a sentencing error under Hurst, and the error was not harmless. View "Jeffries v. State" on Justia Law

The Supreme Court granted Petitioner’s petition for a writ of habeas corpus, vacated Petitioner’s death sentence, and remanded to the circuit court for a new penalty phase. In his habeas petition, Petitioner sought relief under Hurst v. Florida, 477 U.S. __ (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). The Supreme Court granted relief, holding (1) because the jury in Petitioner’s case recommended the death penalty by a vote of eleven to one, Petitioner’s death sentence violated Hurst; and (2) because it cannot be said that there is no reasonable possibility that the error did not contribute to the sentence, the Hurst error in Petitioner’s sentencing was not harmless beyond a reasonable doubt. View "Bailey v. Jones" on Justia Law

The Supreme Court affirmed the postconviction court’s order denying Robert Peterson post-conviction relief as to the guilt phase of Peterson’s criminal trial and denied Peterson’s separate habeas petition. The court, however, concluded that Peterson was entitled to a new penalty phase under Hurst v. State, 202 So. 3d 40 (Fla. 2016). Peterson was convicted of first-degree murder and evidence tampering and was sentenced to death. The jury recommended death by a vote of seven to five. Peterson appealed the denial of his postconviction motion. The Supreme Court held (1) Peterson was not entitled to relief as to his ineffective assistance of guilt phase counsel claim; but (2) the Hurst error during Peterson’s penalty phase was not harmless beyond a reasonable doubt, warranting a new penalty phase proceeding. View "Peterson v. State" on Justia Law