Articles Posted in Florida Supreme Court

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The Supreme Court affirmed Defendant’s convictions of first-degree murder and six sentences of death, holding that no reversible error occurred in the proceedings below and that each of the death sentences was appropriate. Specifically, the Supreme Court held (1) the trial court did not abuse its discretion when it declined Defendant’s request for self-representation; (2) there was no improper doubling of aggravators; (3) Defendant’s challenge to the constitutionality of the death penalty was procedurally barred; (4) Defendant’s guilty pleas were knowing, intelligent, and voluntary; and (5) each of Defendant’s death sentences was proportionate. View "Damas v. State" on Justia Law

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The Supreme Court quashed the decision of the Fifth District Court of Appeal expressly construing a provision of the Florida Constitution and upheld the validity of an ordinance proposing an amendment to the Orange County Charter with the exception of certain language discussed in this opinion, holding that the language was in direct conflict with Fla. Stat. 100.041. The proposed amendment provided for term limits and non-partisan elections for county constitutional officers. Three Orange County constitutional officers filed a suit for declaratory and injunctive relief against the County challenging the county ordinance. The trial court upheld the portion of the charter amendment providing for term limits but struck down that portion providing for nonpartisan elections. The Fifth District affirmed. The Supreme Court quashed the decision below and upheld the validity of the ordinance upon the severance therefrom of offending language requiring the county constitutional officers to be elected during the primary election, holding that the offending language in the amendment for county constitutional officers to be elected on a nonpartisan basis may be stricken without rendering the remainder incomplete. View "Orange County, Florida v. Singh" on Justia Law

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The Supreme Court approved the result reached by the First District Court of Appeal affirming the trial court’s rejection of Petitioners’ challenge to the State’s K-12 public education system based on the State’s alleged failure to comply with Fla. Const. art. IX, 1(a), holding that Coalition for Adequacy & Fairness in School Funding, Inc. v. Chiles (Coalition), 680 So. 2d 400 (Fla. 1996) defeated Petitioners’ claim. In their complaint, Petitioners sought a declaration that the State was breaching its duty to make adequate provision for an “efficient” and “high quality” system of free public schools that allows students to obtain a high quality education. Petitioners requested that the courts order the State to establish a remedial plan including studies to determine what resources are necessary to provide a high quality education to Florida students. The trial court rejected Petitioners’ challenge, and the court of appeal affirmed. The First Circuit affirmed, holding that because Petitioners failed to present any manageable standard by which to avoid judicial intrusion into the powers of the other branches of government, the court of appeal properly affirmed the trial court’s rejection of Petitioners’ blanket challenge to the adequacy of the funding of the entire K-12 education system. View "Citizens for Strong Schools, Inc. v. State Board of Education" on Justia Law

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The Supreme Court affirmed the order of the postconviction court denying Appellant’s motion filed pursuant to Fla. R. Crim. P. 3.851, holding that Hurst v. State, 202 So. 3d 40 (Fla. 2016), did not apply retroactively to Appellant’s sentence of death. Appellant was convicted of first-degree murder and sentenced to death. The jury recommended death by a vote of seven to five. Appellant’s death sentence became final in 1993. In his postconviction motion, Appellant sought relief pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst. The Supreme Court affirmed the postconviction court’s order denying relief, holding that Appellant was not entitled to relief under Hurst. View "Thompson v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Appellant’s motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding, among other things, that Appellant’s attorney was not ineffective for failing to investigate and present certain mitigation evidence. Appellant was convicted of kidnapping and first-degree murder and sentence of death. In her motion for postconviction relief Appellant raised fourteen initial claims and then amended her motion to add a Hurst claim. The trial court denied the motion in its entirety. The Supreme Court affirmed, holding that trial counsel’s performance was not deficient, the State did not commit a Giglio violation, and Appellant was not entitled to a new penalty phase under Hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State, 202 So. 3d 40 (Fla. 2016). View "Allen v. State" on Justia Law

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The Supreme Court quashed the decision of the Fifth Circuit Court of Appeal expressly declaring valid Fla. Stat. 775.082(10), holding that subsection (10) violates the Sixth Amendment to the United States Constitution. In the decision on review, the Fifth District expressly declared subsection (10) valid in the context of rejecting Defendant’s argument that her state prison sentence violated the Sixth Amendment because the jury did not find that she presented a danger to the public under section 775.082(10). Section 775.082(1) requires that a qualifying offender whose sentencing scoresheet totals twenty-two points or fewer be sentenced to a nonstate prison sanction unless the trial court makes written findings that a nonstate prison sanction could present a danger to the public. The Supreme Court quashed the decision below, holding that subsection (10) violates the Sixth Amendment because it requires the court, not the jury, to find the fact of dangerousness to the public that is necessary to increase the statutory maximum nonstate prison sanction. View "Brown v. State" on Justia Law

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The Supreme Court reversed certain portions of the decision of the Second District Court of Appeal holding that chapter 2000-439, section 18, Laws of Florida (the LMHS Lien Law) is invalid under the Florida Constitution, holding that the Second District should not have reached the question of whether the LMHS Lien Law violates the constitutional prohibition against the impairment of contracts under article I, section 10 because the issue was not properly before the court. Specifically, the Supreme Court held (1) the Second District correctly found that the LMHS Lien Law violates article III, section 11(a)(9) of the Florida Constitution as a special law pertaining to the “creation, enforcement, extension or impairment of liens based on private contracts”; (2) the Second District erred in addressing the contract-impairment issue because the Attorney General was not served with proper notice as to that issue under Fla. R. Civ. P. 1.071; and (3) a discussion of statutory damages was unnecessary in light of the determination that the LMHS Lien Law cannot be enforced due to its unconstitutionality. View "Lee Memorial Health System v. Progressive Select Insurance Co." on Justia Law

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The Supreme court affirmed the circuit court’s order granting in part and denying in part Appellant’s motion for DNA testing under Fla. R. Crim. P. 3.853, holding that none of Appellant’s claims on appeal had merit. After a retrial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed on direct appeal. Appellant later filed his motion for DNA testing of evidence pursuant to Rule 3.853. After an evidentiary hearing, the circuit court granted the motion in part and denied it in part. Appellant appealed the circuit court’s partial denial of his Rule 3.853 motion. The Supreme Court affirmed, holding (1) the circuit court did not err in adopting the State’s reasoning and conclusions as to Appellant’s motion in its order; and (2) the partial denial of Appellant’s motion did not violate his Fifth, Eighth, or Fourteenth Amendment rights. View "Gosciminski v. State" on Justia Law

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The Supreme Court agreed with the Fifth District Court of Appeal’s conclusion that Appellant presented no basis for declaring Florida’s hazing statute, Fla. Stat. 1006.63, unconstitutional, thus affirming Appellant’s convictions of manslaughter, felony hazing resulting in death, and two counts of misdemeanor hazing. Defendant was convicted in connection with the activities of the Florida A&M University’s marching band. On appeal, the Fifth District affirmed Defendant’s convictions, rejected his arguments challenging the constitutionality of section 1006.63, and expressly declared that the hazing statute was valid. The Supreme Court affirmed, holding that the hazing statute is neither unconstitutionally overbroad nor void for vagueness. View "Martin v. State" on Justia Law

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The Supreme Court quashed the decision of the First District Court of Appeal holding that it was appropriate for an appellate court to review the entire evidentiary record to determine whether multiple convictions violate double jeopardy, holding that, consistent with State v. Shelley, 176 So. 3d 914 (Fla. 2015), to determine whether multiple convictions of solicitation of a minor, unlawful use of a two-way communications device, and traveling after solicitation of a minor are based upon the same conduct for purposes of double jeopardy, the reviewing court should consider only the charging document. Defendant moved to dismiss the charges against him, arguing that they violated double jeopardy because the elements of solicitation of a minor and unlawful use of a two-way communications device were subsumed within the elements of traveling after solicitation. The trial court denied the motion, and Defendant was convicted of all three counts. The First District affirmed after examining the entire record, concluding that there was no double jeopardy violation. The Supreme Court reversed, holding that the reviewing court should have considered only the charging document in determining whether Defendant’s convictions were based upon the same conduct for purposes of double jeopardy. View "Lee v. State" on Justia Law