Justia Constitutional Law Opinion Summaries

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

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended death by a vote of ten-to-two. The trial court sentenced Defendant to death. The Supreme Court affirmed on direct appeal. Defendant later filed an amended motion to vacate his conviction and sentence under Fla. R. Crim. P. 3.851. The trial court denied the motion. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of postconviction relief and denied the habeas petition, holding (1) the postconviction court properly denied relief on Defendant’s Rule 3.851 motion; and (2) Defendant was not entitled to habeas relief. View "Bogle v. State" on Justia Law

After a second jury trial, Defendant was found guilty of both first-degree premeditated murder and felony murder, with burglary as the underlying felony. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s convictions but vacated his death sentence, holding (1) the trial court did not err in denying Defendant’s motion for mistrial based on juror misconduct; (2) the evidence presented by the State was sufficient to support the first-degree premeditated murder conviction and the first-degree felony murder conviction; (3) the trial court did not commit reversible error by allowing the instruction on felony murder based on burglary to go to the jury; (4) the trial court did not err in denying Defendant’s motion for change of venue; and (5) Hurst error occurred because the recommendation of death in this case was not unanimous, and the error was not harmless. Remanded for a new penalty phase proceeding. View "Dubose v. State" on Justia Law

Hojan was charged with armed robbery, armed kidnapping, attempted murder, and two murders arising out of the 2002 robbery of and shooting of employees at a Waffle House. A surviving victim gave law enforcement officers a taped statement, in which she identified Mickel and Hojan, known to her, as being involved. The jury recommended death by a vote of nine to three, and the trial court followed that recommendation, finding six aggravators, one statutory mitigator, and two nonstatutory mitigators. After an unsuccessful direct appeal, Hojan sought post-conviction relief, arguing that the survivor’s statement to an officer was not an excited utterance; the trial court improperly treated Hojan’s waiver of the opportunity to present mitigating evidence in the penalty phase as a waiver of his opportunity to present motions challenging the death penalty; his confession should have been suppressed; Florida’s death penalty statute is unconstitutional. The Supreme Court of Florida affirmed the denial of relief, finding no error under Hojan’s asserted claims, that sufficient evidence exists, and that the death sentence is proportional. The court nonetheless granted Hojan a new penalty phase, based on the U.S. Supreme Court’s 2016 decision in Hurst v. Florida. View "Hojan v. Florida" on Justia Law

In 2006, a jury found Knight guilty of two counts of first-degree murder for the deaths of his housemate, Stephens, and her four-year-old child. Police, responding to a 911 call about noises in the apartment, found the bodies. All of the doors were locked and the apartment had not been ransacked. Knight was found outside, with cuts and bloodstains. Fingernail scrapings taken from the victim contained Knight’s DNA profile; the victim’s blood was found on Knight’s clothing. In jail, Knight described the crime to another inmate. The jury unanimously recommended a death sentence for each murder. The court sentenced Knight to death, finding that the state had proven beyond a reasonable doubt statutory aggravating circumstances: a previous conviction of another violent capital felony, that the murder was especially heinous, atrocious, or cruel, and that one victim was under 12 years of age. The court found no statutory mitigating circumstances but found eight nonstatutory mitigators. After unsuccessful appeals, Knight sought post-conviction relief, arguing he was improperly denied access to public records; the one-year deadline in Florida Rule of Criminal Procedure was unconstitutionally applied to him; he was denied adversarial testing at the guilt and penalty phases; the rule prohibiting juror interviews is unconstitutional; and Florida’s lethal injection protocol is unconstitutional. The circuit court denied all of Knight’s claims. The Supreme Court of Florida affirmed, rejecting several claims of ineffective assistance, claims of Brady violations, and challenges to the death penalty. View "Knight v. Florida" on Justia Law

In 1999, Mack’s family found Mack’s body, naked from the waist down, with a cord wrapped around her neck. Durousseau’s DNA was found inside Mack’s vagina. In 2003, Durousseau was indicted for first-degree murder for the deaths of five women. The similar methodology of the crimes caused investigators to conclude that Mack was one of Durousseau’s victims. Durousseau was convicted of Mack’s murder. The jury voted to impose a death sentence. The court found four aggravating factors: Durousseau was previously convicted of a felony involving the use or threat of violence; the murder was committed while the defendant was engaged in the commission of a robbery or sexual battery, was committed for pecuniary gain, and was especially heinous, atrocious, or cruel. The court did not find any statutory mitigating circumstances, but found 16 nonstatutory mitigating circumstances and sentenced Durousseau to death. The Supreme Court affirmed. Durousseau sought post-conviction relief, arguing that counsel was ineffective for failing to request additional physical and psychiatric testing and for failing to conduct meaningful voir dire. Before the hearing, Durousseau abandoned his first claim. The court denied Durousseau’s claim. While his appeal was pending, the U.S. Supreme Court decided Hurst v. Florida (2016), holding that Florida’s death penalty sentencing statute violated the Sixth Amendment. The Supreme Court of Florida affirmed the denial of post-conviction relief but vacated Durousseau’s sentences under Hurst because the jury did not make any of the requisite factual findings beyond a reasonable doubt. View "Durousseau v. Florida" on Justia Law