Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of four counts of first-degree murder, four counts of conspiracy to commit murder, two counts of manslaughter, and other crimes. The jury recommended by a vote of ten to two that Defendant be sentenced to death for one murder and also recommended a death sentence for another murder by a vote of nine to three. The trial court followed the jury’s death-sentence recommendations. The Supreme Court affirmed Defendant’s first-degree murder convictions and sentences of death on direct appeal. Defendant later filed a motion to vacate his convictions and sentences pursuant to Fla. R. Crim. P. 3.851, setting forth eight claims. The trial court denied Defendant’s Rule 3.851 motion. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the trial court’s denial of postconviction relief as to all claims except Defendant’s claim relating to the constitutionality of his penalty phase, denied habeas relief, vacated Defendant’s death sentences, and remanded for a new penalty phase, holding that Defendant’s death sentence was unconstitutional under Hurst v. Florida. View "Smith v. State" on Justia Law

Cary Michael Lambrix was convicted and sentenced to death for the 1983 first-degree murder of two victims. The Supreme Court affirmed Lambrix’s murder convictions and death sentences on direct appeal. After the Governor signed a death warrant and the execution was set, Lambrix filed both a successive motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851 and a motion for postconviction DNA testing pursuant to Fla. R. Crim. P. 3.853. The postconviction court summarily denied both of Lambrix’s motions. Lambrix appealed those orders and filed a petition for writ of habeas corpus. After the U.S. Supreme Court issued its opinion in Hurst v. Florida, the Supreme Court permitted supplemental briefing and oral argument to consider the impact of Hurst in this case. The Supreme Court ultimately affirmed the postconviction court’s denial of relief and denied Lambrix’s separate petition for habeas corpus, holding (1) Lambrix was not entitled to a new penalty phase based on Hurst v. Florida or Hurst v. State; and (2) the other grounds that Lambrix raised were devoid of merit. View "Lambrix v. State" on Justia Law

After a jury trial, Appellant was found guilty of two counts of first-degree murder and related crimes. The jury recommended death on both counts of murder. The trial court followed the jury’s recommendation and imposed two death sentences. The Supreme Court affirmed Appellant’s convictions, vacated his death sentence, and remanded for a new penalty phase based on an error in jury selection. Upon resentencing, the jury again recommended death for both murders. The trial judge sentenced Defendant to death for each count of first-degree murder. The Supreme Court affirmed the sentences of death. Appellant later filed a motion to vacate convictions for first-degree murder and sentences of death under Fla. R. Crim. P. 3.851, alleging that both guilt and penalty phase counsel were ineffective under Strickland v. Washington. The postconviction court denied each of Appellant’s claims. The Supreme Court vacated Appellant’s sentences of death, holding (1) the postconviction court did not err in denying relief on Appellant’s ineffective assistance of guilty phase counsel claim; (2) the Court declines to address Appellant’s ineffective assistance of penalty phase counsel claim; and (3) any Hurst error in Appellant’s sentencing was not harmless beyond a reasonable doubt. View "Ault v. State" on Justia Law

Dale Lee Norman was charged with open carrying of a weapon in violation of Fla. Stat. 790.053, Florida’s Open Carry Law. Section 790.053 permits individuals to carry firearms in public so long as the firearm is carried in a concealed manner. After the jury found Norman guilty of the sole count of openly carrying a firearm in violation of Florida’s Open Carry Law, the county court certified three questions to the Fourth District Court of Appeal regarding the constitutionality of the law. The Fourth District upheld Florida’s Open Carry Law under intermediate scrutiny. The Supreme Court affirmed, holding (1) the State has an important interest in regulating firearms as a matter of public safety, and Florida’s Open Carry Law is substantially related to this interest; and (2) therefore, Florida’s Open Carry Law violates neither the Second Amendment to the U.S. Constitution nor article I, section 8 of the Florida Constitution. View "Norman v. State" on Justia Law

Defendant was charged with the murder of her husband. Defendant filed a motion to suppress statements she made to police on two occasions at the police station after being interrogated by the police. The trial court granted the motion to suppress, finding that Defendant was in custody for the purpose of administering Miranda warnings based on the totality of the circumstances, and because she was not advised of her Miranda rights, the statements must be suppressed. The Fifth District Court of Appeal reversed, concluding that “a reasonable person in Defendant’s position would have felt free to terminate the interviews.” The Supreme Court quashed the Fifth District’s decision, holding that Defendant was in custody for purposes of Miranda warnings during both interrogations, and therefore, Defendant’s constitutional right against self incrimination was violated by the police’s failure to administer Miranda warnings before proceeding with the custodial interrogations. Remanded. View "Myers v. State" on Justia Law

Petitioner was involved in a single-vehicle car crash in which a single fatality occurred. After a jury trial, Petitioner was found guilty of DUI serious bodily injury and sentenced to five years of incarceration. Petitioner appealed, arguing that the trial court erred by admitting the results of a blood test because the law enforcement officer did not have probable cause to believe Petitioner was under the influence of alcoholic beverages before requiring him to submit to the blood draw taken after the traffic accident, as required by Fla. Stat. 316.1933(1)(a). The Third District Court of Appeal affirmed, ruling that the blood draw was constitutionally permissible under the fellow officer rule and, alternatively, that voluntary consent supported the blood draw. The Supreme Court quashed the decision of the Third District, holding (1) the fellow officer rule was inapplicable because there was no communication between the officers concerning Petitioner; and (2) Petitioner’s consent was involuntary because it was given in response to a threat to suspend his driver license for refusing to give consent by an officer lacking probable cause. View "Montes-Valeton v. State" on Justia Law

After a jury trial, Appellant was found guilty of the kidnapping and murder of Vincent Binder. The jury recommended that Appellant be sentenced to death by a unanimous vote. The trial court agreed with the jury’s unanimous vote and imposed a death sentence. The Supreme Court affirmed, holding (1) the trial court did not err in overruling the State’s use of a peremptory challenge to an African-American juror; (2) excluding people from the jury venire due to their age does not violate the Constitution; (3) the trial court did not err in permitting the State to introduce evidence of other crimes or acts for the purpose of proving a material fact in issue; (4) the cumulative effect of any improper closing comments made by the prosecutor did not entitle Appellant to a new trial; (5) the trial court’s rulings during the penalty phase did not deprive Appellant of a fair trial; (6) Appellant was not entitled to relief under Hurst v. Florida and Hurst v. State; and (7) the death penalty was not disproportionate. View "Truehill v. State" on Justia Law

Here the Supreme Court considered two petitions for writs of prohibition filed in Evans v. State and Rosario v. State. In Evans, the trial court determined that it would death qualify the jury in Evans’ first-degree murder trial and instruct the jury that Evans could receive a death sentence if the jury unanimously made the requisite findings of fact and unanimously recommended a death sentence. In Rosario, the trial court determined that the State was prohibited from seeking the death penalty in a pending prosecution and ordered that the case proceed with a mandatory life maximum penalty. The Fifth District Court of Appeal granted the State’s petition for a writ of prohibition. The Supreme Court denied Evans’ and Rosario’s petitions for writs of prohibition, holding that the trial courts in both cases may proceed with death qualifying juries, as, pursuant to the Court’s holdings in Hurst v. State and Perry v. State, the revised statutory scheme in chapter 2016-13, Laws of Florida, can be applied to pending prosecutions for a jury recommendation of death if twelve jurors unanimously determine that a defendant should be sentenced to death. View "Evans v. State" on Justia Law

In 2015, the Florida Legislature amended the Woman’s Right to Know Act. The amendments constituted the Mandatory Delay Law (the Law), which imposes an additional twenty-four hour waiting period on women seeking to terminate their pregnancies. Petitioners filed a complaint challenging the validity of the Law as a violation of, inter alia, the constitutional privacy rights of Florida women. Petitioners then filed a motion for a temporary injunction grounded on the right of privacy challenge set forth in their complaint. The trial court issued an order granting Petitioners' request for a temporary injunction, finding that the Law infringed Florida women’s fundamental right of privacy. Accordingly, the court applied the strict scrutiny standard of review. The First District Court of Appeal overturned the trial court’s order granting the temporary injunction. The Supreme Court quashed the First District’s decision, holding (1) the trial court properly applied strict scrutiny when reviewing the Law; (2) the First District misapplied and misconstrued Supreme Court precedent by placing the initial evidentiary burden on Petitioners to prove a significant restriction on Florida’s constitutional right of privacy before subjecting the Law to strict scrutiny; and (3) the trial court correctly found that Petitioner established a substantial likelihood of success on the merits. View "Gainesville Woman Care, LLC v. State" on Justia Law

Defendant was convicted and sentenced to death for the first-degree premeditated murder of a corrections officer. The Supreme Court affirmed Defendant’s convictions and sentence. Defendant later filed a motion to vacate his judgment of conviction and sentence pursuant to Fla. R. Crim. P. 3.851, alleging ineffective assistance of counsel and that his execution will violate his constitutional rights. The postconviction court denied relief. Defendant appealed and also filed a petition for writ of habeas corpus, claiming that the jury instructions in capital sentencing are unconstitutional and that trial counsel was ineffective in litigating constitutional challenges to Florida’s capital sentencing statute. The Supreme Court affirmed the postconviction court’s denial of Defendant’s postconviction motion, holding (1) Defendant failed to demonstrate that the postconviction court erred in finding that no Strickland error occurred; (2) Defendant’s claim of possible incompetence at the time of execution was not ripe for review; and (3) Defendant failed to establish that he was entitled to habeas relief. View "Hall v. State" on Justia Law