Justia Constitutional Law Opinion Summaries

In 1995, Glen Edward Rogers murdered Tina Marie Cribbs in Hillsborough County, Florida. Rogers was convicted of first-degree murder, armed robbery, and grand theft of a motor vehicle. He was sentenced to death, and his conviction and sentence were affirmed on direct appeal. Rogers has since filed multiple postconviction motions, all of which have been denied.Rogers' fourth successive postconviction motion raised three claims: (1) he was unconstitutionally deprived of the right to challenge his conviction and sentence due to a conflict of interest with his counsel, (2) newly discovered evidence of his childhood sexual abuse and trafficking would result in a life sentence on remand, and (3) Florida’s lethal injection procedures are cruel and unusual due to his porphyria diagnosis. The postconviction court summarily denied these claims as untimely, procedurally barred, and/or meritless.The Supreme Court of Florida reviewed the case and affirmed the postconviction court's denial. The court found that Rogers' conflict-of-counsel claim was procedurally barred and without merit, as there was no actual conflict of interest. The newly discovered evidence claim was also found to be procedurally barred and meritless, as the evidence could have been discovered with due diligence. Lastly, the court held that Rogers' method-of-execution claim was untimely and meritless, as he failed to demonstrate that Florida’s lethal injection protocol would cause him substantial and imminent risk of serious illness and needless suffering, and he did not identify a viable alternative method of execution.The Supreme Court of Florida denied Rogers' motion for a stay of execution and his request for oral argument, affirming the summary denial of his fourth successive postconviction motion. View "Rogers v. State" on Justia Law

Jeffrey G. Hutchinson was convicted of murdering his girlfriend Renee Flaherty and her three children in 1998. After an argument with Renee, Hutchinson drank heavily, returned to her home with a shotgun, and killed Renee and two of her children with single shots to the head. He then shot the third child, Geoffrey, twice, killing him. Hutchinson called 911, admitting to the shootings, and was found by police with gunshot residue on his hands and body tissue from Geoffrey on his leg. He was charged with four counts of first-degree murder and sentenced to death for the murders of the three children.Hutchinson's convictions and death sentences were affirmed on direct appeal by the Florida Supreme Court. He filed multiple postconviction motions, all of which were denied. His initial state postconviction motion and successive motions were also denied, as were his federal habeas petitions. His fourth successive postconviction motion, filed after the Governor signed a death warrant, was denied by the circuit court without an evidentiary hearing.The Supreme Court of Florida reviewed Hutchinson's appeal of the denial of his fourth successive postconviction motion and his habeas corpus petition. The court affirmed the circuit court's denial, rejecting Hutchinson's claims that the warrant period violated his constitutional rights, that the warrant selection process was arbitrary, and that his execution would be cruel and unusual punishment. The court also denied his habeas claims, including his argument that Atkins v. Virginia should extend to individuals with neurocognitive disorders and his challenge to the heinous, atrocious, or cruel (HAC) aggravator. The court denied Hutchinson's requests for a stay and oral argument, and ordered the mandate to issue immediately. View "Hutchinson v. State" on Justia Law

Michael A. Tanzi was sentenced to death for the murder of Janet Acosta. On March 10, 2025, Governor Ron DeSantis signed a death warrant scheduling Tanzi’s execution for April 8, 2025. Tanzi sought relief in the circuit court, which was denied, leading to his appeal to the Supreme Court of Florida.The circuit court had previously denied Tanzi’s first motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, and the Florida Supreme Court affirmed this denial. Tanzi’s petition for state habeas relief was also denied. He then sought federal habeas relief, which was denied by the district court and affirmed by the Eleventh Circuit. Tanzi’s subsequent motion for postconviction relief under Hurst v. Florida was denied by the Florida Supreme Court, which found the Hurst error in his case harmless beyond a reasonable doubt.The Supreme Court of Florida reviewed Tanzi’s appeal of the denial of his third motion for postconviction relief, which raised claims about due process violations due to the compressed warrant period, the constitutionality of Florida’s lethal injection protocols, and the Governor’s authority in determining the timing of death warrants. The court affirmed the circuit court’s summary denial of these claims, finding them either procedurally barred or without merit. The court also denied Tanzi’s habeas petition, which argued that his death sentence was unconstitutional under Erlinger v. United States, and dismissed his emergency petition to invoke the court’s all writs jurisdiction.The Supreme Court of Florida held that the warrant litigation schedule did not violate Tanzi’s due process rights, the denial of public records requests was not an abuse of discretion, and the lethal injection protocol did not constitute cruel and unusual punishment. The court also upheld the Governor’s authority in signing death warrants and found no merit in Tanzi’s habeas petition. The court denied all of Tanzi’s motions and requests, including a stay of execution. View "Tanzi v. State" on Justia Law

Kevin Vericker published an internet blog questioning the credentials, character, and competency of Norman Christopher Powell, who was appointed as the attorney for North Bay Village. Powell filed a defamation lawsuit against Vericker, claiming the blog posts were defamatory per se. Vericker responded with a motion for summary judgment and an anti-SLAPP motion, arguing that Powell, as a public official, needed to prove actual malice, which he could not. The trial court denied Vericker's motion.Vericker then sought a writ of certiorari from the Third District Court of Appeal to review the denial of his anti-SLAPP motion. The Third District held that certiorari was not appropriate for reviewing such orders, aligning with the Fourth District's position that public policy favors interlocutory review through rule amendments rather than expanding certiorari jurisdiction. The Third District certified conflict with the Second District's decisions in Gundel, Baird, and Davis, which had allowed certiorari review for anti-SLAPP motions.The Supreme Court of Florida reviewed the case and held that denials of anti-SLAPP motions do not constitute irreparable harm sufficient to support certiorari relief. The court emphasized that the Anti-SLAPP statute does not provide immunity from suit but rather aims for the expeditious resolution of meritless, speech-targeted lawsuits. To align with legislative intent, the court amended Florida Rule of Appellate Procedure 9.130(a)(3) to allow interlocutory review of nonfinal orders denying anti-SLAPP motions. The court approved the Third District's decision and disapproved the Second District's conflicting decisions. View "Vericker v. Powell" on Justia Law

Debbie Mayfield, a former member of the Florida House of Representatives and Florida Senate, sought to run in a special election for Senate District 19 after the incumbent announced his resignation. Mayfield submitted the necessary paperwork to qualify for the ballot, but the Secretary of State and Director of the Division of Elections refused to place her on the ballot, citing a constitutional provision on term limits.The Circuit Court did not review the case. Mayfield directly petitioned the Supreme Court of Florida for writs of mandamus and quo warranto, arguing that the Secretary misinterpreted his authority and failed to fulfill his statutory duty.The Supreme Court of Florida reviewed the case and granted Mayfield's petition for mandamus relief. The court held that Mayfield had a clear legal right to appear on the ballot, as she had met all statutory requirements for qualification. The court found that the Secretary's role in reviewing candidate qualifications is ministerial and does not include the authority to assess a candidate's constitutional eligibility. The court also rejected the Secretary's interpretation of the term-limits provision, concluding that Mayfield's break in service meant she had not served more than eight consecutive years in the Senate. The court ordered the Secretary to place Mayfield on the ballot by a specified deadline and denied the petition for quo warranto as moot. View "Mayfield v. Secretary, Florida Department of State" on Justia Law

James D. Ford was convicted of the 1997 murders of Greg and Kimberly Malnory at a sod farm in South Florida. Ford, who worked with Greg, had planned to go fishing with the couple. Greg was shot in the head, beaten, and had his throat slit. Kimberly was raped, beaten, and shot. Their young daughter was found nearby, unharmed but exposed to the elements. Ford was convicted of two counts of first-degree murder, sexual battery with a firearm, and child abuse, and was sentenced to death.Ford's convictions and sentences were affirmed on direct appeal, and the U.S. Supreme Court denied certiorari in 2002. Ford has since filed multiple unsuccessful postconviction relief motions in state and federal courts. His third successive motion for postconviction relief, filed under Florida Rule of Criminal Procedure 3.851, was summarily denied by the circuit court. This motion raised claims that his death sentence was unconstitutional under Roper v. Simmons due to his mental and developmental age and that executing him would violate his rights under the Fifth, Sixth, Eighth, and Fourteenth Amendments in light of Erlinger v. United States.The Supreme Court of Florida reviewed the case and affirmed the circuit court's denial. The court held that Ford's claim regarding his mental and developmental age was untimely and without merit, as Roper does not extend to individuals over eighteen, regardless of mental age. The court also found that Erlinger, which involved the federal Armed Career Criminal Act, was not applicable to Ford's case. Additionally, the court rejected Ford's arguments related to Hurst v. Florida and Hurst v. State, noting that these decisions do not apply retroactively to Ford's case. The court concluded that Ford's claims were procedurally barred and meritless, and affirmed the denial of his third successive motion for postconviction relief. View "Ford v. State" on Justia Law

Matthew Dettle was charged and convicted of three felonies in Florida: using a computer to solicit a child for unlawful sexual conduct, traveling to meet a minor after such solicitation, and using a two-way communications device to facilitate a felony. His conviction for the third offense was vacated. Dettle argued that his remaining two convictions violated the Double Jeopardy Clause of the U.S. Constitution, which prohibits multiple punishments for the same offense.The First District Court of Appeal found that Dettle's convictions for traveling to meet a minor and unlawful use of a two-way communications device violated double jeopardy and vacated the latter conviction. However, it affirmed his convictions for solicitation and traveling, as they were based on separate illegal acts. Dettle's convictions became final in 2017. After the Florida Supreme Court's decision in Lee v. State, which held that courts should only consider the charging document to determine double jeopardy violations, Dettle sought retroactive relief under this new rule.The Supreme Court of Florida reviewed whether the rule in Lee should apply retroactively. The court concluded that Lee does not apply retroactively to cases that were already final when it was decided. The court reasoned that the rule in Lee is procedural, not substantive, and does not meet the high bar for retroactive application under either the Witt or Teague standards. Consequently, the court affirmed the decision of the First District Court of Appeal, denying Dettle's request for postconviction relief. View "Dettle v. State of Florida" on Justia Law

Adam Richardson, a citizen and taxpayer, petitioned the Supreme Court of Florida for writs of quo warranto and mandamus, alleging that the Governor, Attorney General, and Secretary of the Florida Agency for Health Care Administration (AHCA) violated section 104.31, Florida Statutes, by advocating against a proposed constitutional amendment (Amendment 4) related to abortion rights. Richardson claimed that their actions, including statements on an AHCA webpage and social media, as well as participation in a public call and opinion piece, unlawfully interfered with the vote on Amendment 4.The lower courts did not review this case as it was directly brought to the Supreme Court of Florida. Richardson argued that the respondents' actions violated a statute limiting political activities of state officers and employees, which he believed should be enforced through extraordinary writs.The Supreme Court of Florida denied the petition. The court held that the writ of quo warranto is traditionally used to test the right of a person to hold an office or exercise a state-derived power, not to compel criminal prosecution or enable private enforcement of a criminal statute. The court found that Richardson's grievances were more about the merits of the respondents' actions rather than their authority to act. Additionally, the court denied the writ of mandamus, stating that Richardson did not establish a clear legal right or an indisputable legal duty on the part of the respondents, nor did he show that there was no other adequate remedy available. The court concluded that no further relief was required to complete the exercise of its jurisdiction and denied the petition without permitting a rehearing. View "Richardson v. Secretary, Florida Agency for Health Care Administration" on Justia Law

John Sexton was convicted of the first-degree murder of Ann Parlato, a 94-year-old woman he knew from cutting her lawn. The crime was particularly brutal, involving severe physical trauma and post-mortem mutilation. A jury initially recommended the death penalty by a 10-2 vote, and the Florida Supreme Court upheld the conviction but remanded for a new penalty phase under Hurst v. Florida. On remand, Sexton waived his right to a jury, and the trial court sentenced him to death again.In the lower courts, Sexton moved for the recusal of Judge Mary Handsel, citing a contentious pretrial exchange. Judge Handsel denied the motion but delegated funding decisions to Chief Judge Anthony Rondolino, who granted some requests and denied others, including funding for a PET scan and travel expenses for mitigation specialists. Sexton also waived his right to a jury trial and limited the mitigation evidence presented. The trial court took judicial notice of the original trial transcripts and sentenced Sexton to death, citing three aggravating factors and giving little weight to the mitigating factors.The Supreme Court of Florida reviewed the case and addressed eight issues raised by Sexton. The court found no abuse of discretion in denying funding for a PET scan and travel expenses, noting that Sexton failed to show a particularized need or prejudice. The court also held that the trial court erred in calling Sexton's mitigation specialist as a witness but deemed the error harmless. The court found no violation of Sexton's rights in the trial court's judicial notice of prior proceedings, denial of the motion to disqualify, or comments on Sexton's silence. The court concluded that the trial court properly considered mitigating evidence and understood its discretion in sentencing. Finally, the court rejected Sexton's constitutional challenge to Florida's capital sentencing scheme. The Supreme Court of Florida affirmed Sexton's death sentence. View "Sexton v. State of Florida" on Justia Law

In 1994, Loran Cole and his companion encountered John Edwards and his sister while they were camping. Cole murdered John and raped his sister. Cole was indicted and found guilty of first-degree murder, kidnapping, robbery, and sexual battery. The jury recommended the death penalty, which the trial court imposed. Cole's convictions and death sentence were affirmed on direct appeal, and his certiorari petition was denied by the U.S. Supreme Court in 1998.Cole filed multiple postconviction relief motions, all of which were denied by the circuit court and affirmed by the Florida Supreme Court. His claims included ineffective assistance of counsel, newly discovered evidence, and constitutional challenges. Cole also sought federal habeas relief, which was denied. His subsequent motions for postconviction relief, including claims based on newly discovered evidence and Hurst v. Florida, were also denied.The Florida Supreme Court reviewed Cole's fourth successive motion for postconviction relief and his public records requests. Cole argued newly discovered evidence regarding his treatment at the Dozier School for Boys, Eighth Amendment violations due to his prison conditions, and the unconstitutionality of Florida's lethal injection procedures. The postconviction court denied these claims as untimely, procedurally barred, or without merit. The Florida Supreme Court affirmed the postconviction court's decision, finding no error in the summary denial of Cole's claims and public records requests. The court also denied Cole's motion to stay his execution and his request for oral argument. View "Cole v. State of Florida" on Justia Law