Justia Constitutional Law Opinion Summaries

Articles Posted in Florida Supreme Court
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The Supreme Court affirmed the sentence of death imposed on Defendant after a new penalty phase ordered by the Supreme Court, holding that there was no error in the proceedings below.Defendant was convicted of first-degree murder. The trial court sentenced Defendant to death. The Supreme Court remanded for a new penalty phase pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016), after, after a new penalty phase, the jury returned a unanimous verdict recommending that Defendant be sentenced to death. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding that Defendant failed to show error, much less prejudicial error. View "Deviney v. State" on Justia Law

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The Supreme Court struck a proposed amendment that would add a new section to Fla. Const. art. X, 33, holding that the language in the ballot summary indicating that the proposed qualifiedly "[p]ermits" the use and distribution of recreational marijuana was affirmatively misleading.The Attorney General petitioned the Supreme Court for an advisory opinion regarding the validity of an initiative petition titled "Adult Use of Marijuana." At issue was whether the proposed amendment complied with the single-subject requirement of Fla. Const. art. XI, 3 and whether the ballot title and summary complied with the clarity requirements of Fla. Stat. 101.161(1). The Supreme Court struck the proposed amendment, holding that the initiative petition was clearly and conclusively defective on the ground that the ballot summary failed to comply with Fla. Stat. 101.161. View "Advisory Opinion to Attorney General Re: Adult Use of Marijuana" on Justia Law

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The Supreme Court affirmed Defendant's convictions of first-degree murder, sexual battery of a person under twelve years old, and kidnapping, and the imposition of the death penalty, holding that there was no prejudicial error in this case.Specifically, the Supreme Court held (1) the trial court did not commit fundamental error in failing to grant Defendant's motion for change of venue; (2) the trial court did not abuse its discretion in denying Defendant's motion for a mistrial on account of the interruption to the testimony of the state's expert; (3) the trial court did not abuse its discretion in denying Defendant's motion to exclude autopsy photographs during certain testimony; (4) Defendant was not entitled to relief on his claim that the state made inappropriate comments in its opening statement and in closing argument; and (5) there was no cumulative error in this case. View "Smith v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder and his sentence of death, holding that Defendant failed to demonstrate any reversible error.Defendant pleaded guilty to first-degree murder and was sentenced to death. Defendant appealed, raising ten allegations of error. The Supreme Court affirmed, holding (1) the trial court did not err in allowing Defendant to represent himself during trial; (2) the trial court did not err in accepting Defendant's guilty plea; (3) the trial properly renewed the offer of counsel at all critical stages of the proceedings; (4) there was no reversible error in the trial court's findings on the statutory aggravators alleged by the State and on certain statutory and non statutory mitigators; (5) any error in the trial court's inclusion of a sentencing recommendation in the presentence investigation report did not rise to the level of fundamental error; and (6) Defendant was not entitled to relief on his remaining allegations of error. View "Woodbury v. State" on Justia Law

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The Supreme Court struck in its entirety an amendment to the Hillsborough County Charter adopted in an initiative election that approved a transportation surtax and directives for allocating the tax proceeds, holding that the spending directives were unconstitutional.The charter amendment at issue enacted a one percent transportation sales surtax and included various provisions governing the use and distribution of the tax's proceeds. Here, the Supreme Court reviewed the circuit court's judgment validating the Hillsborough County Commission's authorization of the issuance of bonds to be funded by a portion of the proceeds of the surtax. The Supreme Court reversed the judgment of the circuit court to the extent that it upheld the validity of any portion of the amendment, holding that core provisions of the amendment were inconsistent with the surtax statute and because the invalid provisions and the remaining provisions of the amendment form an interlocking plan, the amendment was unconstitutional in its entirety. View "Emerson v. Hillsborough County" on Justia Law

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The Supreme Court affirmed Defendant's two first-degree murder convictions and two corresponding sentences of death, holding that Defendant's assignments of error were unavailing.Specifically, the Supreme Court held (1) the trial court did not err in instructing on and finding the CCP aggravator and the HAC aggravator; (2) the trial court did not err in instructing on and finding the HAC aggravator; (3) Florida’s death penalty statute is constitutional; (4) the trial court did not abuse its discretion in rejecting Defendant's two proposed impairment mitigators; (5) the trial court did not err in allowing victim impact evidence; (6) the prosecutor’s penalty phase closing argument did not violate Defendant's constitutional rights; and (7) competent, substantial evidence supported Defendant's first-degree murder convictions. View "Colley v. State" on Justia Law

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The Supreme Court affirmed Defendant's first-degree murder conviction and sentence of death, holding that any error in the proceedings below was not prejudicial.Defendant pleaded guilty to the first-degree murder of his cellmate. The trial court accepted the plea, finding that it was freely, voluntarily, knowingly and intelligently given. The trial court sentenced Defendant to death. The Supreme Court affirmed, holding (1) the trial court erred in one aspect of how it handled mitigation, but the error did not prejudice Defendant; (2) the trial court did not fundamentally error by failing to determine beyond a reasonable doubt that the aggravating factors were sufficient to justify the death penalty; (3) the trial court’s failure to enter a written order finding Defendant competent to proceed after orally announcing its competency finding did not constitute fundamental error; and (4) Defendant's guilty plea was knowingly, intelligently, and voluntarily entered. View "Craft v. State" on Justia Law

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The Supreme Court held that the conformity clause of Fla. Const. art. I, 17 precluded the Court from analyzing death sentences for comparative proportionality in the absence of a statute establishing that review.Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant's sentence of death. The trial court later vacated Defendant's death sentence and ordered a new penalty phase proceeding pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016). The trial court subsequently sentenced Defendant to death. On appeal, Defendant argued that his death sentence was disproportionate in comparison to other cases in which the Court upheld the imposition of the death penalty. The State urged the Court to recede from precedent holding that the Court must review the comparative proportionality of every death sentence because comparative proportionality review violates the conformity clause. The Supreme Court agreed, holding that the conformity clause expressly forecloses this court's imposition of a comparative proportionality review requirement that is predicated on the Eighth Amendment. View "Lawrence v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction for first-degree murder and his sentence of death, holding that no error occurred in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion in denying Defendant's request for self-representation as equivocal; (2) the trial court did not abuse its discretion in denying Defendant's peremptory challenge to an African American juror; (3) the trial court did not err in instructing the penalty phase jury; (4) the trial court did not abuse its discretion by admitting statements made by Defendant's prior victim in support of the prior violent felony aggravator; (5) competent, substantial evidence supported the trial court's finding of the HAC aggravator and the CCP aggravator; (6) Craven’s death sentence was proportionate; and (7) the evidence was sufficient to support Defendant's conviction for first-degree murder. View "Craven v. State" on Justia Law

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The Supreme Court affirmed the decision of the circuit court denying Tina Lasonya Brown's motion to vacate her conviction of first-degree murder and sentence of death under Fla. R. Crim. P. 3.851 and denied Brown's petition for a writ of habeas corpus, holding that Brown was not entitled to relief.As to Brown's postconviction appeal, the Supreme Court held (1) the circuit court did not err in denying Brown's allegations of ineffective assistance of counsel in some respects but erred in denying Brown's allegations of ineffective assistance of counsel in other respects; (2) there was no reasonable probability that bur for trial counsel's deficiencies, individually or cumulatively, the outcome would have been different; (3) the circuit court did not err in denying Brown's claim of newly discovered evidence; and (4) the circuit court did not err in summarily denying Brown's claim that she was not entitled to relief from her death sentence under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). As to Brown's habeas petition, the Supreme Court held that appellate counsel was not ineffective on direct appeal. View "Brown v. State" on Justia Law