Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the order of the circuit court summarily denying Defendant's second successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851, holding that there was no error.After a jury trial, Defendant was found guilty of four counts of first-degree murder. After a bench penalty phase, the trial court sentenced Defendant to death. At issue was Defendant's second successive postconviction motion asserting four claims for relief. The circuit court summarily denied all of Defendant's claims. The Supreme Court affirmed, holding that the circuit court did not err in summarily denying Defendant's second successive motion for postconviction relief. View "Hutchinson v. State" on Justia Law

The Supreme Court held that, subject to the procedural constraints of Fla. R. Crim. P. 3.800(b), a trial court has the inherent authority to sua sponte correct sentencing documents that overreport the amount of jail time served by a defendant previous to sentencing or the amount of jail time and prison time served by a defendant prior to sentencing.Rather than defer to the Department of Correction the calculation of Defendant's prison credit, the clerk erroneously calculated the totals of jail and prison credit, resulting in sentencing documents that not only overreported the amount of Defendant's credit for time served but did not distinguish between jail and prison credit. The Supreme Court held that the sua sponte corrections to Defendant's sentencing documents, which the trial court made after Defendant's appeal was over, were untimely and could not stand. View "Spear v. State" on Justia Law

Ritchie sexually battered and strangled to death nine-year-old F.W., who had been left in Ritchie’s care by a friend, then dumped the child’s body in the water off of the Courtney Campbell Causeway and fabricated a story about her disappearance. The Florida Supreme Court affirmed his conviction for first-degree murder and his sentence of death. The court rejected claims that the cumulative impact of improper comments by the prosecutor during the penalty phase closing argument deprived Ritchie of a fair penalty phase; Florida law regarding the presentation of victim impact evidence is unconstitutional on its face and as applied in his case; the trial court erred in ordering audio redactions to a mitigation video submitted by Ritchie and by allowing the state to present improper rebuttal evidence to the video; and the cumulative prejudicial effect of the trial errors alleged in issues one through three deprived him of a fair penalty phase. Ritchie’s case is not one where the “jury recommendation of death could not have been obtained without the assistance of” the errors. The aggravators “greatly outweighed” the scant mitigation. The court acknowledged that the state easily could have avoided the errors that occurred and that similar errors, particularly if preserved, might be outcome-determinative in a closer case. View "Ritchie v. State of Florida" on Justia Law

The Supreme Court held that a sentencing court may rely on a defendant's lack of remorse after the defendant has given a post-Miranda, sworn confession to the crime and has obviously lied under oath at trial about his guilt.Defendant gave a sworn confession to the crimes of which he was convicted but retracted the confession during his trial testimony. The district court felt "constrained" to reverse Defendant's sentence on the grounds that the trial court improperly relied on Defendant's subsequent claim of innocence in imposing the sentence. The Supreme Court quashed the decision of the First District Court of Appeal, which vacated Defendant's aggregate 300-year sentence and remanded for resentencing, holding that the court was under no obligation to ignore the "freely offered statements" that Defendant made during trial rather than at allocution. View "State v. Burns" on Justia Law

The Supreme Court affirmed the judgment of the circuit court summarily denying Appellant's third amended successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851 and denying his motion to correct illegal sentence filed pursuant to Fla. R. Crim. P. 3.800(a), holding that there was no error.Appellant was convicted of three counts of first-degree murder, two counts of arson, and grand theft. Appellant was sentenced to death for each murder. The Supreme Court affirmed. Appellant later filed the postconviction motion at issue and a rule 3.800(a) motion arguing that his death sentences were illegal. The circuit court summarily denied the postconviction motion and also denied his rule 3.800(a) motion. The Supreme Court affirmed, holding that Appellant's claims were not timely raised. View "Pittman v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's second successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851, holding that there was no error.The State charged Appellant with first-degree murder. Following a second trial, a jury found Defendant guilty and recommended a sentence of death. The Supreme Court reversed due to a jury selection error. On remand, a jury again found Defendant guilty. The trial court sentenced him to death. The Supreme Court affirmed, holding that the circuit court did not err in denying Appellant's newly discovered evidence and Brady claims. View "Valentine v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court summarily denying Defendant's seventh motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that the trial court did not err in summarily denying relief.The State charged Defendant with first-degree murder and other crimes. Defendant pled guilty to each of the charged offenses, and the trial court sentenced him to death. After the death sentence became final, Defendant sought postconviction relief in state and federal courts, without success. Defendant later brought the postconviction motion at issue on appeal arguing that the trial court's failure to conduct a hearing pursuant to Hall v. Florida, 572 U.S. 701 (2014), constituted reversible error. The Supreme Court affirmed, holding that Defendant could not succeed on his Hall-based intellectual disability claim, and therefore, the trial court did not err in summarily denying that claim. View "Thompson v. State" on Justia Law

The Supreme Court sanctioned Petitioner, an inmate in state custody, holding that Petitioner failed to show cause why he should not be barred.Petitioner was convicted of first-degree murder and robbery with a gun or deadly weapon. Since 2009, Petitioner demonstrated a pattern of vexatious filing of meritless pro se requests for relief in this Court related to his case, including the pro se petition in the instant case, which the Supreme Court treated as a petition for writ of habeas corpus. The Supreme Court dismissed the petition and directed the clerk of court to reject any future pleadings or other requests for relief unless such filings are signed by a member in good standing of The Florida Bar. View "Rivera v. Dixon" on Justia Law

The Supreme Court held that conviction on multiple counts under Fla. Stat. 316.062(2) stemming from a single crash involving multiple victims does not expose a defendant to multiple punishments for one offense in violation of constitutional double jeopardy protections.Under section 316.027, when a car crash results in the injury or death of "a person," the driver of a vehicle involved in the crash must stop and remain at the scene until fulfilling the requirements of Fla. Stat. 316.062, which requires the driver to provide identifying information to any injured person and the police and to render reasonable assistance to any injured person. Defendant was convicted of four violations of section 316.027(2), one violation for each victim of one crash. The court of appeal vacated two of Defendant's three convictions as violating double jeopardy principles. The Supreme Court quashed the decision below, holding (1) section 316.027(2) contemplates a per-crash-victim unit of prosecution rather than on a per-crash basis; and (2) therefore, Defendant's separate convictions for each crash victim were not multiple punishments for the same offense. View "State v. Johnson" on Justia Law

The Supreme Court approved the holding of the court of appeal that Fla. Const. art. I, 14 does not prohibit the trial court the discretion at first appearance, upon a finding of probable cause that the defendant committed a crime punishable by capital punishment or life imprisonment, to defer ruling on bail and to detain the defendant for a reasonable time to conduct a "full" Arthur bond hearing, holding that there was no error.Defendant was arraigned on one count of robbery using a firearm or deadly weapon. After a hearing held pursuant to State v. Arthur, 390 So. 2d 717 (Fla. 1980) the trial court concluded that the evidence was sufficient to convict Defendant of unarmed robbery and granted him pretrial release and bail in the amount of $25,000. On appeal, Defendant argued that the first sentence of article 1, section 14 creates a two-step procedure. The court of appeals rejected this argument. The Supreme Court affirmed, holding that article I, section 14 does not prohibit a trial court from detaining a defendant beyond first appearance without setting release unless the court has made a preliminary finding that the proof of guilt is evident or the presumption is great. View "Thourtman v. Junior" on Justia Law