Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was found guilty of two counts of first-degree murder. The jury recommended the death penalty for each murder by a vote of seven to five. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s convictions and sentences of death. Defendant then filed a timely motion for postconviction relief, raising six claims. The circuit court denied the motion for postconviction relief after an evidentiary hearing. The Supreme Court affirmed the denial of relief as to Defendant’s ineffective assistance of guilt phase counsel claim but vacated Defendant’s sentences of death, holding that the Hurst error in Defendant’s case was not harmless beyond a reasonable doubt. Remanded for a new penalty phase proceeding. View "Robards v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree premeditated and felony murder and armed robbery. The jury recommended the death penalty by a vote of eight to four. The trial court sentenced Defendant to death in accordance with the jury’s recommendation. The Supreme Court affirmed Defendant’s convictions but vacated the death sentence, holding (1) the evidence was sufficient to support Defendant’s conviction for first-degree premeditated and felony murder; and (2) Defendant’s death sentence violates Hurst v. State, and the Hurst error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Newberry v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder. The jury recommended death by a vote of ten to two. The trial court followed the jury’s recommendation and sentenced Defendant to death. The Supreme Court affirmed the conviction and sentence. Defendant later filed a motion for postconviction relief. The circuit court denied relief on all claims following an evidentiary hearing. Defendant appealed the denial of postconviction relief and also petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of postconviction relief but vacated the death sentence, holding (1) the circuit court correctly denied relief on Defendant’s ineffective assistance of counsel claims; (2) appellate counsel did not provide ineffective assistance; and (3) Defendant’s death sentence violated Hurst v. State, and the Hurst error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Abdool v. State" on Justia Law

Defendant was convicted of three counts of murder. The trial court followed the jury’s recommendation of death for the murder of a five-year-old girl but sentenced Defendant to life imprisonment for the other two murders. The Supreme Court affirmed. Defendant then filed a motion for postconviction relief. The trial court denied the motion after holding an evidentiary hearing. The Supreme Court affirmed the convictions but vacated the death sentence, holding (1) the trial court properly denied Defendant’s claims that trial counsel provided ineffective assistance; and (2) because the jury recommended the death penalty by a vote of ten to two, Defendant’s death sentence violated Hurst v. State, and the Hurst error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Heyne v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended a sentence of death by a vote of seven to five. The trial court followed the jury’s recommendation and imposed a sentence of death. The Supreme Court affirmed Defendant’s conviction but reversed his death sentence, holding (1) the trial court did not err in denying Defendant’s motions for mistrial during the guilt phase; (2) any error by the State in its statements during closing arguments did not rise to the level of fundamental error; (3) the evidence was sufficient to sustain a felony-murder conviction; but (4) the failure to require a unanimous verdict was not harmless in this case. Remanded to the trial court for a new penalty phase. View "Guzman v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder and armed burglary of a dwelling with discharge of a firearm causing death. The trial court sentenced Defendant to death on both counts of first-degree murder and to life without parole on the burglary charge. Defendant appealed, raising four issues. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in admitting testimony regarding a shotgun that was not used to commit the killings and allowing the shotgun to be admitted into evidence; (2) the trial court did not err in denying Defendant’s motion for mistrial where the prosecutor argued lack of remorse; (3) the trial court did not err in finding that the murder of one of the victims was committed in a cold, calculated, and premeditated manner; (4) any Hurst error in Defendant’s penalty phase was harmless beyond a reasonable doubt; (5) there was sufficient evidence to support a conviction for first-degree premeditated murder; and (6) Defendant’s death sentence was proportionate. View "Oliver v. State" on Justia Law

Defendant was convicted of manslaughter with a firearm and sentenced to thirty years in prison. At sentencing, the trial judge imposed a lump sum of “approximately $956” in fines and court costs. The written order showed that the total included a discretionary fine and surcharge, which were not individually pronounced at sentencing. Defendant appealed. The Fifth District Court of Appeal affirmed, holding (1) the trial court did not err by denying Defendant’s motion for mistrial, and (2) Defendant’s argument that the trial court erred by not individually pronouncing the discretionary fine and surcharge at sentencing was not preserved because it was only a procedural challenge. The Supreme Court quashed the Fifth District’s decision insofar as it conflicts with this decision, holding that trial courts must individually pronounce discretionary fees, costs, and fines during a sentencing hearing to comply with due process requirements. Remanded for resentencing. View "Osterhoudt v. State" on Justia Law

Defendant was convicted of first-degree murder. The jury recommended that Defendant be sentenced to death by a vote of eight to four. The trial court followed the recommendation and imposed a death sentence. The Supreme Court affirmed Defendant’s first-degree murder conviction but vacated his death sentence, holding (1) the State presented sufficient evidence to support the conviction; but (2) the Hurst v. State error in Defendant’s case was not harmless beyond a reasonable doubt, as it was not clear beyond a reasonable doubt that the jury’s failure to unanimously find all the facts necessary for imposition of the death penalty did not contribute to Defendant’s death sentence. Remanded for a new penalty phase. View "White v. State" on Justia Law

Defendant was convicted of attempted second-degree murder of a law enforcement officer and first-degree felony murder of another victim, which was based on the attempted second-degree murder conviction. Defendant received two life sentences. The Fifth District reversed, concluding (1) the jury instructions were erroneous because they did not require the jury to find that Defendant knew that the victim was a law enforcement officer, but (2) Fla. Stat. 782.065 is a reclassification statute that does not create a separate substantive offense, and therefore, Defendant’s conviction of first-degree felony murder was unnecessary. The Supreme Court quashed the Fifth District’s decision to the extent that it held that section 782.065 does not create a substantive offense, holding that the statute is a reclassification statute that creates a substantive offense, and therefore, the proper remedy for the erroneous jury instructions would have been to vacate both of Defendant’s convictions and remand for a new trial. Remanded with directions to order a new trial on the charges of attempted second-degree murder of a law enforcement officer and first-degree felony murder. View "Ramroop v. State" on Justia Law

Defendant was convicted of second-degree murder. Defendant’s jury was instructed on the lesser included offense of manslaughter by act with the same instruction that the Supreme Court found to be fundamentally erroneous in State v. Montgomery. Defendant appealed, arguing that he was entitled to relief in light of Montgomery. The Fourth District Court of Appeal affirmed, thus rejecting the fundamental error claim based on the fact that the trial court also instructed the jury on the lesser included offense of manslaughter by culpable negligence. After the Supreme Court’s decision in Haygood v. State was issued, the Court granted Defendant’s petition for review, summarily quashed the decision of the Fourth District in Dominique I, and remanded for reconsideration in light of the Court’s decision in Haygood. The Fourth District reversed on remand, concluding that fundamental error occurred in the giving of the jury instruction for manslaughter by act, requiring a new trial. The Supreme Court quashed the decision of the Fourth District, holding (1) the evidence in this case reasonably supported the lesser included offense of manslaughter by culpable negligence; and (2) therefore, under Haygood, the giving of the manslaughter by culpable negligence instruction cured the fundamental error in the giving of the erroneous manslaughter by act instruction. View "State v. Dominique" on Justia Law