Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death, holding that Defendant was not entitled to relief on any of his claims of error.Defendant pleaded guilty to first degree murder. After a penalty-phase trial, the court concluded that the aggravating circumstances far outweighed the mitigating circumstances, warranting a sentence of death. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in declining to grant Defendant's motion to continue; (2) the trial court did not err in rejecting two statutory mitigating circumstances; (3) Defendant failed to establish a constitutional defect with Florida's death-penalty statute; (4) Defendant's guilty plea was knowingly, intelligently, and voluntarily given; and (5) Defendant's remaining arguments were without merit. View "Wells v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree murder and his sentence imposed for a Class B1 felony, holding that Defendant was not entitled to relief on his allegations of error.In 2012, the legislature amended North Carolina's murder statute to classify second-degree murders according to varying degrees of severity based on the level of culpability with which the criminal defendant acted. Under the amended statute, most kinds of second-degree murder are classified at the Class B1 felony level, but when it is determined that an offender acted with depraved-heart malice, second-degree murder is classified as a Class B2 felony. In 2019, Defendant was convicted of second-degree murder. At issue was whether Defendant should have been sentenced at the lower B2 felony level, instead of at the class B1 felony level, because the jury concluded that he acted with depraved-heart malice. The Supreme Court affirmed Defendant's sentence, holding that, under the circumstances, the trial court properly sentenced Defendant at the class B1 level because the jury's completed verdict form was not ambiguous. View "Furst v. Rebholz" on Justia Law

The Supreme Court found that Petitioner, who filed a pro se petition for a writ of habeas corpus, failed to show cause why he should not be barred and sanctioned him as set forth in this opinion.Petitioner was convicted of one count of armed robbery with a non-deadly weapon and sentenced to life imprisonment. Including this Petitioner, Petitioner had filed fourteen pro se petitions with the Supreme Court, including the habeas corpus petition at issue. The Supreme Court denied the petition, concluding that the petition was a frivolous proceeding, and directed the clerk of court to reject any future pleadings or other requests for relief submitted by Petitioner, holding that if no action is taken, Petitioner will continue to burden the Supreme Court's resources. View "Green v. Dixon" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's successive postconviction motion filed under Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief on his allegations of error.Appellant was convicted of armed robbery and first-degree murder and was sentenced to death. The Supreme Court affirmed. Appellant later filed the successive motion at issue here seeking vacatur of his death sentence based on allegedly newly-discovered evidence. The trial court concluded that the motion was untimely and then ruled on the merits that the claims did not warrant relief. The Supreme Court affirmed, holding that the circuit court committed no error in summarily denying Appellant's claims. View "Sanchez-Torres v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's latest successive postconviction motion seeking relief under Hall v. Florida, 572 U.S. 701 (2014), holding that Appellant did not get the benefit of Hall.Defendant was found guilty of two counts of first-degree murder and other crimes and sentenced to death. Defendant challenged his death sentence numerous times. Here, Defendant raised a second intellectual disability claim relying on Hall v. Florida, 472 U.S. 701 (2014). The circuit court summarily denied the claim. The Supreme Court reversed and remanded for an evidentiary hearing. After a hearing, the circuit court denied the motion. The Supreme Court affirmed on the basis that Hall was not retroactive, and therefore, his Hall-based intellectual disability claim failed regardless of the evidence presented at his evidentiary hearing. View "Walls v. State" on Justia Law

The Supreme Court affirmed the decision of the circuit court summarily denying Donald David Dillbeck's fourth successive postconviction motion filed under Fla. R. Crim. P. 3.851, denied Dillbeck's habeas petition, and denied two additional motions filed by Defendant, holding that Defendant was not entitled to relief in any form.Dillbeck twice committed murder and sat on death row for several decades. On January 23, 2023 Governor Ron DeSantis signed Dillbeck's death warrant. Dillbeck then filed his fourth successive postconviction motion, arguing that he was exempt from execution on three grounds. The circuit court summarily denied all three claims. Dillbeck appealed, petitioned the Supreme Court for a writ of habeas corpus, moved for a stay of execution, and requested oral argument. The Supreme Court denied all forms of relief, holding that Dillbeck failed to prove any of his allegations of error. View "Dillbeck v. State" on Justia Law

The Supreme Court denied Petitioner's writ of mandamus, which the Supreme Court created as a motion for written opinion, as well as any other pending motions or requests for relief, holding that holding that Petitioner was not entitled to relief and had abused the Court's resources.As of the date of this opinion, Petitioner had filed forty-one pro se petitions or notices with the Court since August 29, 2022. The Supreme Court denied the instant petition and ordered Petitioner to show cause why she should not be barred from filing further pro se requests for relief. The Supreme Court then concluded that Petitioner failed to show cause why she should not be sanctioned and directed the Clerk of Court to reject any future pleadings or requests for relief unless such filings were signed by a member in good standing of The Florida Bar. View "A.C. v. Dep't of Children and Families" on Justia Law

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 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