Justia Constitutional Law Opinion Summaries

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

In 2015, Zachary Penna committed a series of violent crimes in Florida, including two murders. After his arrest, Penna was read his Miranda rights and initially invoked his right to counsel. However, during his hospitalization, Penna voluntarily initiated several conversations with Deputy Michael Nettles, during which he made incriminating statements. Penna was subsequently charged with several crimes, including two counts of first-degree murder. Before trial, Penna moved to suppress the statements made to Deputy Nettles, arguing that they were obtained in violation of Miranda. The trial court denied the motion, and Penna was found guilty on all counts and sentenced to life in prison.Penna appealed to the Fourth District Court of Appeal, which found that the statements during the first two conversations were not obtained in violation of Miranda. However, the court ruled that Deputy Nettles violated Miranda by failing to re-read Penna his Miranda rights prior to the final three conversations. The court relied on its own precedent, which had interpreted a previous Florida Supreme Court decision to require a full re-reading of Miranda warnings under the circumstances of this case. The court found that the error was not harmless, despite the overwhelming evidence of Penna’s guilt.The Supreme Court of Florida accepted the case for review. The court was asked to consider whether a defendant’s Fifth Amendment Miranda rights are automatically violated when an officer fails to re-read a Miranda warning following a defendant’s voluntary re-initiation of contact. The court held that there is no per se requirement that an officer remind or readvise a defendant of his Miranda rights. The court found that the Fourth District Court of Appeal had improperly expanded the requirements of Miranda and receded from its previous decision that had established a categorical rule requiring a full re-reading of Miranda warnings. The court remanded the case for reconsideration under the proper standard. View "State of Florida v. Penna" on Justia Law

In this case, the Attorney General of Florida petitioned the Supreme Court of Florida for an advisory opinion regarding the validity of a proposed citizen initiative amendment to the Florida Constitution, titled "Amendment to Limit Government Interference with Abortion". The proposed amendment was sponsored by Floridians Protecting Freedom, Inc., and sought to limit the government's ability to prohibit, penalize, delay, or restrict abortion before viability or when necessary to protect the patient’s health, as determined by the patient’s healthcare provider.The court approved the proposed amendment for placement on the ballot. In its ruling, the court held that the proposed amendment complied with the single-subject requirement of article XI, section 3 of the Florida Constitution, and that the ballot title and summary complied with section 101.161(1), Florida Statutes. The court also concluded that there is no basis for finding that the proposed amendment is facially invalid under the United States Constitution.The court noted that the ballot summary, which essentially followed the language of the proposed amendment, was an "accurate, objective, and neutral summary of the proposed amendment." Therefore, it concluded that the summary did not mislead voters about what the proposed amendment would achieve. View "Advisory Opinion to the Attorney General re: Limiting Government Interference with Abortion" on Justia Law

The Florida Supreme Court was asked to review a proposed amendment to the state constitution legalizing the recreational use of marijuana. The court evaluated the amendment for adherence to the constitution’s single-subject requirement, the clarity of the ballot summary, and whether the amendment was facially invalid under the federal constitution. The amendment, titled "Adult Personal Use of Marijuana," aimed to modify the Florida Constitution to legalize the personal use of marijuana by adults and allow licensed centers to sell and distribute marijuana for personal use.The court ruled that the amendment adhered to the single-subject requirement as it focused on a single dominant plan or scheme, which is the legalization of marijuana for personal use. The court disagreed with the argument that the amendment violated the single-subject requirement by both decriminalizing and commercializing recreational marijuana, stating that the sale and possession are logically and naturally related as part of a dominant plan or scheme.The court also ruled that the ballot summary met the statutory standard for clarity. The court disagreed with the opposition that the ballot summary was misleading because it implied that there were already other state-licensed entities ready to engage in the sale of recreational marijuana.Lastly, the court ruled that the amendment is not facially invalid under the U.S. Constitution. The court rejected the argument that the proposed amendment is preempted by the federal Controlled Substances Act and thus invalid under the Supremacy Clause.In conclusion, the court approved the proposed amendment for placement on the ballot, finding it complies with the requirements imposed by the Florida Constitution and Florida Statutes. View "Advisory Opinion to the Attorney General Re: Adult Personal Use of Marijuana" on Justia Law

This case before the Supreme Court of Florida concerned a constitutional challenge to an amended Florida statute that prohibits abortions if the gestational age of the fetus is more than 15 weeks, with certain exceptions. The petitioners, a group of abortion clinics and a medical doctor collectively known as Planned Parenthood, alleged that the statute violated the Privacy Clause of the Florida Constitution, which guarantees the right to be let alone and free from government intrusion into private life.While acknowledging the moral, ethical, and policy issues implicated in the subject matter of abortion, the court focused on the Privacy Clause’s text, its context, and the historical evidence surrounding its adoption. The court concluded that there was no basis under the Privacy Clause to invalidate the statute. In reaching this conclusion, the court receded from prior decisions in which it held that the Privacy Clause guaranteed the right to receive an abortion through the end of the second trimester.As such, the court found that the petitioners were not entitled to the temporary injunction granted by the trial court. The court approved the outcome reached by the First District Court of Appeal, which had reversed the temporary injunction on the basis that Planned Parenthood could not establish irreparable harm. Therefore, the Florida statute prohibiting abortions after 15 weeks of gestational age, subject to certain exceptions, was upheld. View "Planned Parenthood of Southwest and Central Florida v. State of Florida" on Justia Law

In this case, two companies and an individual, all involved in Florida's gaming industry, petitioned against the Governor of Florida and others, challenging a gaming compact between the State and the Seminole Tribe. The petitioners argued that a sports betting provision in the compact violated the Florida Constitution, which limits the expansion of casino gambling to the citizens' initiative process. They claimed that the Governor and Legislature exceeded their constitutional authority by allowing the compact to be enacted. The petitioners requested a declaration that the law implementing the compact was unconstitutional and sought an injunction to stop the Seminole Tribe from continuing to operate mobile sports betting.However, the Supreme Court of Florida rejected this petition on the grounds that a writ of quo warranto, which the petitioners used to challenge the compact, was not an appropriate means to question the substantive constitutionality of an enacted law. The court underscored that quo warranto is a common law remedy used to test the right of a person to hold an office or exercise some right derived from the state, not to challenge the constitutionality of a law. Therefore, the petitioners' claim was beyond the relief that quo warranto provides.The petitioners' reliance on previous cases, where the writ of quo warranto was used to question the Governor's authority to bind the state to a compact without ratification by the Legislature, was also rejected. The court pointed out that these cases were fundamentally different as they did not challenge the substance of the agreement enacted by the Governor and ratified by the Legislature.In conclusion, the Supreme Court of Florida denied the petition, stating that the relief sought by the petitioners was beyond what quo warranto provides and declined to extend the scope of the writ to test the substantive constitutionality of a statute. View "West Flagler Associates, Ltd. v. DeSantis" on Justia Law