Justia Constitutional Law Opinion Summaries

Articles Posted in Florida Supreme Court
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In this case, the Supreme Court of Florida denied a petition brought forward by Leonard P. Gonzalez, Jr., who requested a review of a nonfinal order by the circuit court. Gonzalez was convicted of home-invasion robbery and two counts of first-degree murder, for which he was sentenced to death. The circuit court set aside his death sentences, but denied any further relief. Following changes in Florida's death-penalty laws, Gonzalez sought an order declaring that the amended statute does not apply in his case, arguing against its application as unconstitutional and inconsistent with the presumption that substantive statutes apply prospectively. The circuit court disagreed and ruled that the amended statute would apply at his upcoming penalty phase.Gonzalez then petitioned the Supreme Court of Florida, invoking its all-writs authority and authority to issue writs of prohibition, arguing against the circuit court's ruling that the new statute could be lawfully applied at his upcoming penalty phase. However, the Supreme Court of Florida determined that the relief sought is not available by way of prohibition or its all-writs authority. The court concluded that the circuit court has jurisdiction to conduct the new penalty phase and that its decision to apply the new statute does not affect this jurisdiction. The court also clarified that its all-writs provision does not add appellate jurisdiction and is restricted to preserving jurisdiction that has already been invoked or to protect jurisdiction that likely will be invoked in the future. As such, Gonzalez's petition was denied. View "Gonzalez v. State of Florida" on Justia Law

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The Supreme Court affirmed the judgment of the postconviction court summarily denying the claims in Michael Duane Zack, III's fourth successive postconviction motion and denied Zack's motion for stay of execution and request for oral argument, holding that Zack was not entitled to relief.Defendant was sentenced to death for the murder of Ravonne Smith and was scheduled for execution on October 3, 2023. In his successive postconviction motion Defendant claimed that his execution should be barred under the Eighth Amendment. The postconviction court summarily denied the claims as untimely, procedurally barred, and meritless. The Supreme Court affirmed and denied Zack's motion for stay of execution and request for oral argument, holding that the postconviction court did not err by summarily denying Defendant's claims as untimely, procedurally barred, and meritless. View "Zack v. State" on Justia Law

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The Supreme Court denied Appellant's petition for a writ of habeas corpus, holding that Appellant failed to establish that he was entitled to the writ.Appellant was convicted in 1991, following a jury trial, of first-degree murder and kidnapping. Decades later, Appellant filed his petition for a writ of habeas corpus. In his petition, Appellant claimed that Chapter 2017-1, Laws of Florida, created a substantive right that must be retroactively applied under the state and federal Constitutions. The Supreme Court denied relief, holding that this Court had consistently rejected as without merit the claim that chapter 2017-1 created a substantive right that must be retroactively applied, and Appellant's arguments did not compel departing from precedent. View "Arbelaez v. State" on Justia Law

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The Supreme Court affirmed Defendant's convictions of two counts of first-degree murder but set aside and his sentences of death for each murder, holding that Defendant was deprived of his right to "have the Assistance of Counsel for his defense" when the trial court put him to an improper choice at the beginning of the penalty phase proceedings.After the jury returned guilty verdicts for both first-degree murder charges the matter proceeded to the penalty phase. The jury unanimously recommended sentences of death. After a series of Spencer hearings, the trial court sentenced Defendant to death for each murder. The Supreme Court affirmed and remanded the case for a new penalty phase, holding (1) the trial court did not commit reversible error in its evidentiary rulings during Defendant's guilt phase proceedings; (2) Defendant's convictions were supported by competent, substantial evidence; but (3) Defendant's waiver of his right to counsel during the penalty phase was not knowing, intelligent, and voluntary, and Defendant was entitled to a new sentencing hearing based on the trial court's fundamental error in forcing him to abandon counsel during that phase. View "Figueroa-Sanabria v. State" on Justia Law

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The Supreme Court approved the decision of the court of appeal affirming the trial court's denial of Defendant's motion to suppress eyewitness identifications resulting from an out-of-court police procedure, holding that the proper standard of review is abuse of discretion review and that the court of appeal correctly analyzed the merits under that standard.In denying Defendant's motion to suppress, the court of appeal applied the abuse of discretion standard of review to the trial court's ruling on the out-of-court identification by the eyewitness. On appeal, the court of appeal affirmed "[d]ue to the abuse of discretion standard of review." The Supreme Court approved the decision below, holding (1) abuse of discretion review is the proper standard; and (2) the trial court did not abuse its discretion in admitting the out-of-court identification. View "Alahad v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court summarily denying Appellant's sixth successive motion for post-conviction relief under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in summarily denying the motion.Appellant was convicted of first-degree felony murder and armed robbery and was sentenced to death. Decades later, Appellant filed the sixth successive post-conviction motion at issue on appeal, arguing that two pieces of allegedly newly discovered evidence required extending the rationale in Roper v. Simmons, 543 U.S. 551 (2005), for barring the execution of defendants under the age of eighteen at the time of the offense to bar the execution of defendants under the age of twenty-one. The circuit court summarily denied relief. The Supreme Court affirmed, holding that the circuit court did not err in finding that Appellant's claim was untimely and that his request to extend Roper was meritless. View "Melton v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death, holding that Defendant was not entitled to relief on any of his claims of error.Defendant pleaded guilty to first degree murder. After a penalty-phase trial, the court concluded that the aggravating circumstances far outweighed the mitigating circumstances, warranting a sentence of death. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in declining to grant Defendant's motion to continue; (2) the trial court did not err in rejecting two statutory mitigating circumstances; (3) Defendant failed to establish a constitutional defect with Florida's death-penalty statute; (4) Defendant's guilty plea was knowingly, intelligently, and voluntarily given; and (5) Defendant's remaining arguments were without merit. View "Wells v. State" on Justia Law

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The Supreme Court denied petitions in these consolidated cases alleging that the nomination of nonresident candidates for a judicial vacancy was unconstitutional, holding that the constitutional residency requirement for judges attaches at the time of appointment - not at the time of nomination.After new legislation authorized several new judgeships the Governor asked the judicial nominating commission of both the Fifth District Court of Appeal, which had four vacancies, and the Sixth District Court of Appeal, which had three vacancies, to convene and submit nominees for his consideration. Petitioners filed separate petitions seeking a writ of quo warranto directed to each judicial nominating commission alleging that the each commission's list of nominees violated the Florida Constitution and the commissions' rules of procedure because the lists included individuals who did not reside in the territorial jurisdiction of the court of appointment at the time of nomination. The Supreme Court denied the writ, holding that the residency requirement contained in Ky. Const. art. V, 8 attaches at the time of appointment. View "Boan v. Fla. Fifth District Court of Appeal Judicial Nominating Comm'n v. Fla. Sixth District Court of Appeal Judicial Nominating Comm'n" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder and his corresponding death sentence, as well as Defendant's conviction for conspiracy to commit murder, holding that Defendant was not entitled to relief on any of his allegations of error.On appeal, Defendant raised numerous challenges to his convictions and death sentences. The Supreme Court affirmed the judgment in its entirety, holding (1) there was no merit to Defendant's arguments regarding the guilt phase of his trial; and (2) Defendant's claims regarding the penalty phase of his trial were also without merit. View "Sievers v. State" on Justia Law

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The Supreme Court approved of the decision of the First District Court of Appeal affirming Defendant's conviction for sexual battery in violation of Fla. Stat. 794.011(5)(b), holding that subsection 5(b) is not facially unconstitutional because it does not remove the State's burden to prove the defendant's general intent to engage in the act that constitutes the offense under the statute.On appeal, Defendant argued that subsection 5(b) was facially unconstitutional or must be read to include a requirement that the State prove that a criminal defendant knew or should have known the victim did not consent to sexual intercourse. The First District affirmed, disagreeing with Defendant that section 794.011(5)(b) was unconstitutional because it does not require the State to prove a defendant's mens rea. The Supreme Court affirmed, holding that the Legislature's reach did not approach the extent of its constitutional grasp where the statute makes sexual battery a crime of general intent not a strict liability offense. View "Statler v. State" on Justia Law