Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was found guilty of first-degree murder. The jury recommended death by a vote of ten to two. The trial court followed the jury’s recommendation and sentenced Defendant to death. The Supreme Court affirmed the conviction and sentence. Defendant later filed a motion for postconviction relief. The circuit court denied relief on all claims following an evidentiary hearing. Defendant appealed the denial of postconviction relief and also petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of postconviction relief but vacated the death sentence, holding (1) the circuit court correctly denied relief on Defendant’s ineffective assistance of counsel claims; (2) appellate counsel did not provide ineffective assistance; and (3) Defendant’s death sentence violated Hurst v. State, and the Hurst error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Abdool v. State" on Justia Law

Defendant was convicted of three counts of murder. The trial court followed the jury’s recommendation of death for the murder of a five-year-old girl but sentenced Defendant to life imprisonment for the other two murders. The Supreme Court affirmed. Defendant then filed a motion for postconviction relief. The trial court denied the motion after holding an evidentiary hearing. The Supreme Court affirmed the convictions but vacated the death sentence, holding (1) the trial court properly denied Defendant’s claims that trial counsel provided ineffective assistance; and (2) because the jury recommended the death penalty by a vote of ten to two, Defendant’s death sentence violated Hurst v. State, and the Hurst error was not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Heyne v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended a sentence of death by a vote of seven to five. The trial court followed the jury’s recommendation and imposed a sentence of death. The Supreme Court affirmed Defendant’s conviction but reversed his death sentence, holding (1) the trial court did not err in denying Defendant’s motions for mistrial during the guilt phase; (2) any error by the State in its statements during closing arguments did not rise to the level of fundamental error; (3) the evidence was sufficient to sustain a felony-murder conviction; but (4) the failure to require a unanimous verdict was not harmless in this case. Remanded to the trial court for a new penalty phase. View "Guzman v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, robbery, fleeing and eluding, and resisting arrest with violence. At the penalty phase of trial, the jury recommended death by a vote of ten to two. The trial court followed the recommendation and sentenced Defendant to death. The Supreme Court affirmed the trial court’s denial of Defendant’s guilt phase claims but reversed and remanded for a new penalty phase, holding that because the non unanimous jury did not make the findings required under Hurst v. State, the error was not harmless, and Defendant was entitled to a new penalty phase under Hurst v. Florida, as interpreted by the Supreme Court in Hurst v. State. View "Bradley v. State" on Justia Law

After a jury trial, Defendant was convicted of premeditated or felony murder, robbery, and sexual battery. The jury recommended the death penalty by a vote of seven to five. The trial judge followed the recommendation and sentenced Defendant to death. Defendant appealed his death sentence. The Supreme Court affirmed. Defendant later filed the instant motion for postconviction relief, presenting, inter alia, ineffective assistance of counsel. The postconviction court denied all claims. Defendant appealed the denial of his motion, raising claims of ineffective assistance of resentencing phase counsel and ineffective assistance of postconviction counsel. Defendant also petitioned for a writ of habeas corpus, alleging ineffective assistance of appellate counsel. The Supreme Court vacated Defendant’s death sentence and remanded for a new penalty phase, holding that Defendant was entitled to a new penalty phase pursuant to Hurst v. Florida, as interpreted by the Court’s decision in Hurst v. State. View "Orme v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury returned a recommendation in favor of death by a vote of eight to four. The trial court accepted the recommendation and sentenced Defendant to death. The Supreme Court affirmed the conviction and vacated the death sentence, holding (1) it cannot be concluded beyond a reasonable doubt that a Hurst v. Florida error did not contribute to Defendant’s sentence; and (2) the trial court properly denied Defendant’s motion for judgment of acquittal, and there was no error in the guilt phase of trial. Remanded for a new penalty phase. View "Deviney v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, kidnapping, and home invasion robbery. At the conclusion of the penalty phase, the jury recommended death by a vote of nine to three. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s convictions and sentences. Defendant then filed a postconviction motion pursuant to Fla. R. Crim. P. 3.851. The trial court denied all relief after an evidentiary hearing. Defendant appealed the denial of his postconviction motion and also filed a petition for a writ of habeas corpus. The Supreme Court reversed the trial court’s denial of Defendant’s claim related to the constitutionality of Florida’s death penalty scheme, vacated Defendant’s death sentence as unconstitutional under Hurst v. Florida, and denied habeas relief, holding (1) the Hurst error in Defendant’s penalty phase was harmless beyond a reasonable doubt, and Defendant was entitled to a new penalty phase; and (2) Defendant’s remaining claims were unavailing. View "Baker v. State" on Justia Law

Appellant was convicted of first-degree murder, sexual battery with a deadly weapon, and other offenses. The trial court sentenced Appellant to death for the murder conviction. The Supreme Court affirmed Appellant’s convictions but reversed his sentences, holding (1) no prejudicial error occurred during the guilt phase of Appellant’s trial; but (2) Appellant’s death sentence was not based upon factual findings by a jury of his peers, as required by the Sixth Amendment, but upon a nonunanimous jury recommendation, and the Hurst v. Florida errors that occurred during sentencing were not harmless beyond a reasonable doubt. Remanded for a new penalty phase. View "Jackson v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder. The jury recommended the death sentence by a vote of ten to two. The Supreme Court affirmed the conviction and the death sentence. Thereafter, Appellant filed a motion for postconviction relief under Fla. R. Crim. P. 3.851, raising twelve claims. The trial court denied relief. The Supreme Court affirmed the postconviction court’s oder as to Appellant’s conviction but vacated the death sentence and remanded for a new penalty phase, holding (1) Appellant was not denied the effective assistance of counsel under Strickland v. Washington; but (2) in light of the nonunanimous jury recommendation to impose a death sentence, it cannot be said that the failure to require a unanimous verdict in this case was harmless. View "Hodges v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder, two counts of kidnapping, two counts of robbery, and one count of carjacking. The trial court sentenced Defendant to death for each murder and life imprisonment for each of his other convictions. The Supreme Court affirmed Defendant’s convictions and sentences. Defendant later filed an amended motion to vacate his judgment and sentences and a renewed motion for determination of intellectual disability. The postconviction court denied both motions. The Supreme Court affirmed, holding (1) the postconviction court properly determined that Defendant is not among those intellectually disabled defendants that cannot be executed; (2) with regard to every claim raised in Defendant’s amended motion to vacate his judgment and sentences, Defendant failed to demonstrate that the postconviction court erred in finding no Strickland error occurred; and (3) Defendant was not entitled to relief pursuant to Hurst v. Florida. View "Wright v. State" on Justia Law