Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of two counts of first-degree murder. The jury recommended death sentences for the murder convictions, and the trial court sentenced Defendant to death. The Supreme Court affirmed the convictions but vacated Defendant’s death sentences, holding (1) the trial court did not err by denying Defendant’s motion to suppress his confession and the corresponding video recording of it; (2) the trial court did not abuse its discretion by precluding a false confession expert from testifying that Defendant’s statement to law enforcement was coerced; (3) the trial court did not err by advising the jury that the ultimate decision to impose the death penalty rested with the court; (4) the evidence was sufficient to support the first-degree murder convictions; but (5) the term-of-years sentences imposed against Defendant’s codefendants precluded Defendant’s death sentences. View "McCloud v. State" on Justia Law

Appellant was convicted of first-degree murder and sentenced to death. After the United States Supreme Court ruled in Atkins v. Virginia that it was unconstitutional to execute persons with intellectual disabilities, Appellant raised claims that he was intellectually disabled and could not be executed. The trial court and Supreme Court denied relief, relying, in part, on the bright-line cutoff of an IQ score of 70 that was subsequently invalidated in theUnited States Supreme Court’s holding in Hall v. Florida. This appeal concerned Appellant’s seventh motion for postconviction relief, alleging that his death sentence violated the Eighth and Fourteenth Amendments under Atkins. The postconviction court summarily denied Appellant’s motion. The Supreme Court reversed, holding that failing to give Appellant the benefit of Hall would result in a manifest injustice, which is an exception to the law of the case doctrine. Remanded for a new evidentiary hearing regarding intellectual disability, to be conducted pursuant to Hall. View "Thompson v. State" on Justia Law

After a jury trial, Appellant was convicted of three counts of first-degree murder, one count of attempted first-degree murder, one count of armed robbery, and one count of first-degree arson. The trial court imposed two sentences of death. Defendant appealed his convictions and sentences. The Supreme Court affirmed the trial court’s judgments of conviction and sentences of death, holding (1) the trial court properly admitted the statements of one victim as a dying declaration; (2) the trial court did not err in admitted certain out-of-court and in-court identifications of Appellant; (3) the trial court did not err in admitting nearly four dozen autopsy and hospital photographs of the murder victims; (4) the trial court properly found that Appellant committed the murder of one victim in order to avoid arrest; (5) competent, substantial evidence of guilt supported Appellant’s convictions; and (6) Appellant’s death sentences satisfied the Court’s proportionality requirement. View "Davis v. State" on Justia Law

Defendant was charged with one count of possession of a firearm by a convicted felon. Defendant moved to dismiss the charge, arguing (1) his rifle was a permissible antique firearm or replica thereof under Fla. Stat. 790.23, the felon-in-possession statute, and (2) section 790.23 is unconstitutionally vague if convicted felons are prohibited from possessing black-powder rifles. The trial court denied the motion to dismiss, and Defendant entered a plea of no contest to one count of constructive possession of a firearm by a convicted felon. The First District Court of Appeal reversed, holding that section 790.23 is unconstitutional with respect to the possession of a replica of an antique firearm by a convicted felon. The Supreme Court approved the First District’s reversal of Defendant’s conviction but not its conclusion that section 790.23 is unconstitutionally vague, holding that Defendant was entitled to the statutory exception of the felon-in-possession statute because his firearm was a permissible “replica” of an “antique firearm” under section 790.23, as defined in Fla. Stat. 790.001(1). View "State v. Weeks" on Justia Law

Jacob John Dougan was convicted of a murder that occurred in 1974. Dougan was sentenced to death for the murder. Dougan filed an amended postconviction petition raising twenty-nine claims. The postconviction proceedings lasted more than twenty years. After an evidentiary hearing in 2013, the postconviction court granted relief as to multiple claims and vacated the murder conviction and sentence of death. Specifically, the postconviction court found (1) the State failed to disclose the full extent of its plea deal with William Hearn, the State’s only eyewitness to the murder, and allowed Hearn to testify falsely about the true nature of his deal with the State; and (2) Dougan’s guilt phase counsel was operating under two conflicts of interest and that ineffective assistance of counsel occurred in the guilt phase. The Supreme Court affirmed, holding that Dougan’s trial was tainted by the cumulative effect of the State’s violation of Giglio v. United States through the testimony of Hearn and the substandard performance of Dougan’s counsel, thus depriving Dougan of a fair and impartial trial. View "State v. Dougan" on Justia Law

This case involved a pending prosecution where the death penalty was sought. At issue was whether Florida’s newly enacted death penalty law (the Act), which was passed after the United States Supreme Court in Hurst v. Florida held that a portion of Florida’s capital sentencing scheme was unconstitutional, may be constitutionally applied to pending prosecutions for capital offenses that occurred prior to the new law’s effective date. In State v. Perry, the Fifth District Court of Appeal held that the Act could apply to pending prosecutions without offending the Constitution. The Fifth District then certified two questions of law to the Supreme Court. The Supreme Court answered, holding (1) as decided on remand in Hurst v. State, Hurst v. Florida did not declare Florida’s death penalty unconstitutional, and because Fla. Stat. 775.082(2) is limited to those cases in which the defendant was “previously sentenced to death,” the statute is inapplicable; and (2) the Act cannot constitutionally be applied to pending prosecutions because it does not require unanimity in the jury’s final recommendation as to whether the defendant should be sentenced to death, contrary to the Supreme Court’s holding in Hurst v. State. View "Perry v. State" on Justia Law

In Hurst v. State, the Supreme Court affirmed Defendant’s death sentence, which was imposed after a second penalty phase sentencing proceeding. Defendant sought certiorari review. Upon review, the United States Supreme Court reversed, holding that Florida’s capital sentencing scheme was unconstitutional to the extent that the judge, independent of a jury’s fact-finding, finds the facts necessary for imposition of the death penalty. The Court left it to the Florida Supreme Court to consider whether the error in sentencing was harmless beyond a reasonable doubt. On remand, the Supreme Court held (1) the United States Supreme Court's decision in Hurst v. Florida requires that a jury must unanimously find the critical findings necessary before the trial court may consider imposing a death sentence, and in order for the trial court to impose a sentence of death, the jury’s recommended sentence of death must be unanimous; (2) Fla. Stat. 775.082(2) does not mandate that Defendant receive an automatic life sentence; but (3) the error in Defendant’s sentencing was not harmless beyond a reasonable doubt. Remanded for a new penalty phase proceeding. View "Hurst v. State" on Justia Law

Defendant was charged with one count of possession of a firearm by a convicted felon. Defendant moved to dismiss the charge, contending that his rifle was a permissible antique firearm or “replica” thereof under Fla. Stat. 790.23. Section 790.23 prohibits convicted felons from possessing “any firearm.” In the alternative, Defendant argued that the felon-in-possession statute was unconstitutionally vague if it prohibited convicted felons from possessing black-powder rifles. The trial court denied Defendant’s motion to dismiss and adjudicated him guilty of the offense. The First District Court of Appeal reversed Defendant’s conviction, holding that section 270.23 was unconstitutionally vague. The Supreme Court approved the First District’s reversal of Defendant’s conviction but not its conclusion that section 790.23 is unconstitutionally vague, holding (1) a “replica” of an “antique firearm” under the statutory definition is construed as emphasizing the type of firing system of the replica antique firearm as its distinctive feature; and (2) therefore, Defendant was entitled to the statutory exception of the felon-in-possession statute because his firearm was a permissible “replica” of an “antique firearm.” View "State v. Weeks" on Justia Law

James Wright, who sought election for the office of Mayor in the City of Miami Gardens, tendered a check to qualify as a candidate for the office. The check was returned due to a banking error. After qualifying had ended, Wright was informed of this bank error. Pursuant to Fla. Stat. 99.061(7)(a)1., Wright was disqualified. Wright filed this action seeking declaratory and mandamus relief against the City, the City Clerk, and the Miami-Dade County Supervisor of Elections (collectively, Defendants). Specifically, Wright sought to require Defendants to recognize him as a properly and validly qualified candidate for the office of Mayor in the August 30 election. The trial court denied relief, concluding that section 99.061(7)(a)1. explicitly required the City Clerk to disqualify Wright. The Court of Appeal affirmed. The Supreme Court quashed the decision below, holding that the law unconstitutionally erects a barrier that is an unnecessary restraint on one’s right to seek elective office. The Court, therefore, severed the portion of section 14 of chapter 2011-40, Laws of Florida, that amends section 99.061(7)(a)1. of the Florida Statues and, thus, the version of section 99.061(7)(a)1. in existence prior to the 2011 amendments was revived by operation of law. View "Wright v. City of Miami Gardens" on Justia Law

Petitioner was convicted of two counts of lewd or lascivious molestation for touching the victim’s breasts and touching the victim’s buttocks. The court of appeal affirmed, concluding (1) the trial court did not err in restricting cross-examination of the victim and her mother, and (2) Petitioner’s convictions did not violate double jeopardy. The Supreme Court affirmed Petitioner’s convictions and sentences, holding (1) Petitioner’s dual convictions under the lewd or lascivious molestation statute did not violate double jeopardy; and (2) the trial court did not err in restricting defense counsel’s cross-examination of the victim and her mother. View "Graham v. State" on Justia Law