Justia Constitutional Law Opinion Summaries

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

The case involves a petition for a writ of quo warranto challenging the authority of the Financial Impact Estimating Conference to issue a revised financial impact statement for a proposed constitutional amendment titled “Amendment to Limit Government Interference with Abortion.” The petitioners, Floridians Protecting Freedom and Sara Latshaw, argue that the Estimating Conference acted beyond its authority. The respondents include the Financial Impact Estimating Conference, its four principals, the President of the Florida Senate, and the Speaker of the Florida House of Representatives.The Estimating Conference initially submitted a financial impact statement in November 2023. Following a Florida Supreme Court decision in April 2024, which did not address the financial impact statement, the petitioners filed a declaratory judgment action in circuit court, claiming the original statement was outdated and misleading. The circuit court ruled in favor of the petitioners, remanding the statement for redrafting. The government appealed, but the First District Court of Appeal dismissed the appeal as moot after the Estimating Conference voluntarily issued a revised statement in July 2024. The petitioners then sought relief from the Florida Supreme Court.The Supreme Court of Florida denied the petition for a writ of quo warranto. The Court held that the petitioners waived or forfeited their right to challenge the Estimating Conference’s authority by actively participating in the revision process without objecting to the Conference’s authority. The Court emphasized that the petitioners had accepted the legality of the revision process and focused on influencing the content of the revised statement. Consequently, the Court did not address the merits of the petition or the substantive legality of the revised financial impact statement. View "Floridians Protecting Freedom, Inc. v. Passidomo" on Justia Law

In 1999, Allen Ward Cox, an inmate at Lake Correctional Institute, was indicted for the premeditated murder of fellow inmate Thomas Baker. Cox discovered that $500 had been stolen from his footlocker and offered $50 to anyone who could identify the thief, threatening to kill the person responsible. The next day, Cox attacked Baker, beating and stabbing him with a shank, resulting in Baker's death. Cox was found guilty of first-degree murder and sentenced to death.The Florida Supreme Court affirmed Cox's conviction and death sentence in 2002. After exhausting initial state and federal postconviction proceedings, Cox filed a motion for postconviction relief based on Hurst v. Florida, which was granted in 2017. A new penalty phase trial was ordered, and the jury unanimously recommended the death penalty, finding two aggravating factors: imprisonment and a prior violent felony. The trial court sentenced Cox to death, considering both aggravating and mitigating factors.The Supreme Court of Florida reviewed Cox's appeal, which raised seven issues, including the rejection of certain nonstatutory mitigating factors, the cumulative effect of the prosecutor's comments during closing arguments, and the constitutionality of Florida's death penalty scheme. The court found no abuse of discretion in the trial court's rejection of the mitigating factors, determining that the evidence supported the trial court's findings. The court also concluded that the prosecutor's comments did not constitute fundamental error and upheld the constitutionality of Florida's death penalty scheme based on established precedent.The Supreme Court of Florida affirmed Cox's death sentence, finding no reversible error in the trial court's proceedings. The court did not address the issue raised by the State on cross-appeal, as Cox's convictions and sentences were affirmed. View "Cox v. State" on Justia Law

The case involves James Herard, a member of the "BACC Street Crips," a branch of the national Crips gang. Herard was found guilty of 18 gang-related felonies, including the first-degree murders of Eric Jean-Pierre and Kiem Huynh. The crimes were committed as part of a body-count competition within the gang. Herard was sentenced to death for the murder of Jean-Pierre and life without parole for the murder of Huynh. He appealed his convictions and death sentence.Herard's trial was held in May 2014, where the prosecution presented evidence of incriminating statements made by Herard to law enforcement following his arrest for stealing a pit bull. The defense argued that Herard's statements were inconsistent, unreliable, and involuntary. The jury found Herard guilty on 18 counts and not guilty on a robbery count.In the penalty phase, the jury recommended a death sentence for the murder of Jean-Pierre by a vote of 8 to 4. The trial court found that the State had proven three aggravating circumstances beyond a reasonable doubt and sentenced Herard to death for the Jean-Pierre murder and to life without the possibility of parole for the Huynh murder.The Supreme Court of Florida affirmed the lower court's decision. The court rejected Herard's arguments that the trial court erred in denying his due process-based motion to dismiss, denying his motions to suppress incriminating statements, admitting physical evidence he claimed was unrelated to the crimes charged, excluding his expert witness testimony about false confessions, and sentencing him in a manner that violated the Sixth and Eighth Amendments. The court also found that there was sufficient evidence to sustain Herard’s conviction for the murder of Eric Jean-Pierre. View "Herard v. State of Florida" on Justia Law

The Supreme Court of Florida was asked to interpret Florida’s law prohibiting riot, section 870.01(2), Florida Statutes (2021). The question was whether the law applies to a person who is present at a violent protest, but neither engages in, nor intends to assist others in engaging in, violent and disorderly conduct. The court ruled that it does not.The case originated from a lawsuit filed by a group of plaintiffs against Governor Ron DeSantis, three Florida sheriffs, and Attorney General Ashley Moody in the U.S. District Court for the Northern District of Florida. The plaintiffs argued that the statute was vague and overbroad in violation of the Fourteenth Amendment. The district court agreed and enjoined the enforcement of the statute. On appeal, the U.S. Court of Appeals for the Eleventh Circuit found that the central constitutional question was the statute’s scope and certified the question to the Supreme Court of Florida.The Supreme Court of Florida concluded that a "violent public disturbance" under section 870.01(2) is characterized by harm to persons or property, and not by peacefulness. To "willfully participate" in a "violent public disturbance," a defendant must have "intentionally, knowingly, and purposely" chosen to be part of it. Therefore, to be guilty of the crime of riot, one must "engage in," or at least "intend to assist others in engaging in, violent and disorderly conduct." The court found that the statute was not ambiguous and returned the case to the U.S. Court of Appeals for the Eleventh Circuit. View "DeSantis v. Dream Defenders" on Justia Law

The case revolves around Monique H. Worrell, who was suspended from her position as State Attorney for the Ninth Judicial Circuit by Governor Ron DeSantis through Executive Order 23-160. The order alleged that during Worrell's tenure, the administration of criminal justice in the Ninth Circuit was fundamentally derelict, constituting both neglect of duty and incompetence. The order detailed that Worrell authorized or allowed charging practices that permitted violent offenders, drug traffickers, serious juvenile offenders, and pedophiles to evade incarceration when otherwise warranted under Florida law. It also alleged that Worrell authorized or allowed practices that prevented assistant state attorneys from seeking certain sentencing enhancements and limited charges for possession of child pornography.The Florida Constitution allows the governor to suspend any state officer not subject to impeachment for neglect of duty or incompetence. Worrell, not being subject to impeachment, was constitutionally subject to suspension. The Florida Senate has the power to remove from office or reinstate the suspended official.The Supreme Court of Florida's role was to determine whether the governor had met the constitutional mandate to state the grounds of the officer's suspension. The court's review was deferential, confirming that the governor had specified the applicable grounds for suspension and that the allegations in the suspension order bore a reasonable relation to the asserted basis for the suspension.The Supreme Court of Florida found that the Executive Order passed this test. It named the grounds for Worrell's suspension—neglect of duty and incompetence—and provided various factual allegations that reasonably related to those grounds of suspension. The court disagreed with Worrell's claim that the allegations in the Executive Order were impermissibly vague or that they addressed conduct that fell within the lawful exercise of prosecutorial discretion. Therefore, the court denied Worrell's petition for a writ of quo warranto. View "Worrell v. DeSantis" on Justia Law

The case involves Joshua Lyle Creller, who was charged with resisting an officer without violence and possession of a controlled substance, methamphetamine, following a 2018 traffic stop. Creller refused to comply with a K-9 officer’s command to exit his vehicle during the traffic stop for officer safety. After his arrest, methamphetamine was found on his person. Creller moved to suppress the evidence of its discovery.The trial court denied Creller’s motion to suppress, finding the State’s evidence credible. The court concluded that the officer's request for Creller to exit the vehicle was for officer safety and did not violate the Fourth Amendment’s prohibition of unreasonable searches and seizures. Creller was subsequently convicted by a jury. However, the Second District Court of Appeal reversed the conviction, holding that Creller was unlawfully seized in violation of the Fourth Amendment when the initial traffic stop transformed into a narcotics investigation for which no prior probable cause existed. The court certified conflict with the Fifth District Court of Appeal in State v. Benjamin, which reached the opposite conclusion.The Supreme Court of Florida disagreed with the Second District Court of Appeal's interpretation. The court held that the Fourth Amendment allows a K-9 officer to order a driver to exit a vehicle during a lawful traffic stop for officer safety reasons. The court concluded that the K-9 officer's command to Creller to exit the vehicle was reasonable and did not transform the traffic stop into a narcotics investigation. Therefore, the court quashed the decision of the Second District Court of Appeal and approved the decision of the Fifth District Court of Appeal in State v. Benjamin. View "State of Florida v. Creller" on Justia Law