Justia Constitutional Law Opinion Summaries

After a trial, Defendant was found guilty of murder, sexual battery, kidnapping, burglary, and grand theft. Defendant was sentenced to death for the murder. The Supreme Court affirmed the convictions and sentences. Defendant subsequently filed a motion for postconviction relief, raising seven claims of error. Defendant also filed a petition for a writ of habeas corpus. The trial court denied relief. The Supreme Court affirmed the denial of postconviction relief and denied habeas relief, holding (1) the postconviction court did not err in finding that counsel did not provide constitutionally ineffective assistance during the guilt phase or penalty phase; (2) the postconviction court did not err in denying Defendant’s Brady claim; (3) appellate counsel did not provide ineffective assistance; and (4) Defendant was not entitled to relief under Hurst v. Florida. View "Brant v. State" on Justia Law

Petitioner pled no contest to aggravated child abuse and simple child abuse. Petitioner was sentenced to a term of imprisonment and drug offender probation. The probation contained a special condition prohibiting Petitioner from associating with anyone who was illegally using drugs. Petitioner appealed, arguing that the special condition was improperly vague. The Court of Appeal upheld the special condition. Petitioner then petitioned the Supreme Court for review. The Court approved the Court of Appeal’s decision, holding (1) Petitioner’s special condition of probation, “you will not associate with anyone who is illegally using drugs,” is not unconstitutionally vague; but (2) to prove a violation of the condition the State must prove by a preponderance of the evidence the probationer’s knowledge that the person with whom he or she associated was illegally using drugs at the time of the violation. View "Demott v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder. The trial court sentenced Defendant to death for both murders. The Supreme Court affirmed Defendant’s convictions and sentences on appeal. Defendant subsequently filed an amended motion to vacate his judgment and sentences, alleging ineffective assistance of counsel during both the guilt phase and penalty phase of trial. The postconviction court granted Defendant a new penalty phase, concluding that counsel provided ineffective assistance during the penalty phase and that Defendant was deprived of a fair trial during the penalty phase by the cumulative effect of the errors. The court denied Defendant’s remaining claims. Both the State and Defendant appealed. The Supreme Court affirmed the postconviction court’s order and remanded for a new penalty phase proceeding, holding (1) competent, substantial evidence supported the postconviction court’s findings that Defendant was prejudiced by the deficient performance of his penalty phase counsel; and (2) the postconviction court did not err in finding that Defendant’s trial counsel were not unconstitutionally ineffective during the guilt phase of his trial. View "State v. Bright" on Justia Law

In 2004, when Petitioner was sixteen years old, she and her boyfriend committed murder. Petitioner was convicted of second-degree murder with a weapon, which was classified as a life felony. The trial court sentenced Petitioner to life without parole without indicating what findings of aggravating or mitigating circumstances warranted imposition of the life-without-parole sentence as opposed to a term-of-years sentence under the sentencing guidelines then in place. After the United States Supreme Court decided Miller v. Alabama, Petitioner filed a motion for postconviction relief in the form of resentencing. The circuit court denied the motion. The Second District Court of Appeal affirmed, concluding that because Petitioner was sentenced under a discretionary sentencing scheme, Miller was inapplicable to Petitioner’s life-without-parole sentence. The Supreme Court quashed the Second District’s decision, holding that Miller applies to juvenile offenders whose sentences of life imprisonment without parole were imposed pursuant to a discretionary sentencing scheme when the sentencing court, in exercising that discretion, did not take into account the individualized sentencing considerations of a juvenile offender’s youth. View "Landrum v. State" on Justia Law

This case stemmed from the Department's issuance of a proposed tax assessment on American Business, for taxes and interest on the company’s internet sales transactions. The tax assessment was issued by the Department to American Business pursuant to section 212.05(1)(l) of the Florida Statutes. The court concluded that section 212.05(l) does not violate the dormant Commerce Clause as applied to American Business’s internet sales of flowers, gift baskets, and other tangible personal property where all four prongs of the Complete Auto Transit, Inc. v. Brady test have been satisfied. The court further concluded that no due process violation is present on the facts of this case where American Business’s activities have a substantial nexus to Florida. Accordingly, the court quashed the Fourth District's decision to the extent that it holds that the assessment of sales tax on sales of flowers, gift baskets, and other items of tangible personal property ordered by out-of-state customers for out-of-state delivery violates the dormant Commerce Clause. View "Florida Dept. of Revenue v. American Business USA Corp." on Justia Law

After a jury trial, Defendant was convicted of first-degree murder with a firearm. During the trial, the State presented evidence of Defendant’s pre-arrest, pre-Miranda silence and argued that the jury should consider this silence as evidence of Defendant’s consciousness of guilt. The Court of Appeal reversed and remanded for a new trial, concluding that because Defendant did not testify at trial, the use of her pre-arrest, pre-Miranda silence was precluded as a matter of state constitutional and evidentiary law. The Supreme Court approved of the Court of Appeal’s decision, holding (1) use of a defendant’s silence as substantive evidence of guilt violates the Florida constitutional right against self-incrimination; and (2) as a matter of Florida evidentiary law, the State is precluded from using that silence to argue a defendant’s consciousness of guilt. View "State v. Horwitz" on Justia Law

Appellant was convicted of one count of robbery with a firearm while wearing a mask. Appellant was twenty years old when he committed the crime but twenty-one years old when he was tried and sentenced. If Appellant had been sentenced under the youthful offender statute, he faced a six-year cap as to his sentence. Instead, Appellant was sentenced to the statutory maximum of life in prison. Appellant filed a motion to correct an illegal sentence. The motion was deemed denied. The Court of Appeal affirmed the sentence. Before the Supreme Court, Appellant raised a facial challenge to the constitutionality of Fla. Stat. 958.04(1)(b), arguing that the statute (1) violates equal protection because the age-at-sentencing classification creates arbitrary and irrational distinctions between otherwise eligible defendants, and (2) violates due process because, in attempting to be eligible for youthful offender sentencing, a defendant may forgo certain constitutional rights. The Supreme Court affirmed, holding (1) because section 958.04(1)(b), as amended, bears a rational relationship to a legitimate government objective, it does not violate equal protection; and (2) the statute does not violate due process because it serves a legitimate state interest. View "Jackson v. State" on Justia Law

Defendant entered an open plea to the charge of armed burglary of a dwelling. Before sentencing, the State filed a sentencing memorandum recommending that the court consider a new charge pending against Defendant for burglary of a vehicle. The trial court considered the subsequent charges pending against Defendant at sentencing, declined to sentence him as a youthful offender, and instead sentenced him to twelve years in prison. The Fourth District Court of Appeal affirmed Defendant’s sentence, concluding that the trial court did not violate Defendant’s due process rights during sentencing for the primary offense by considering his subsequent arrest without conviction. The Supreme Court quashed the Fourth District’s decision, holding that a trial court may not consider a subsequent arrest without conviction during sentencing for the primary offense. View "Norvil v. State" on Justia Law

This workers’ compensation case involved the statutory attorney’s fees provision declared unconstitutional in the Supreme Court’s opinion in Castellanos v. Next Door Co. Pursuant to the fee schedule in Fla. Stat. 440.34, the judge of compensation claims was constrained to award the claimant’s attorney $19.44 per hour for 90 hours of work. The First District Court of Appeal was compelled to affirm the $1,750 statutory fee award. The Supreme Court quashed the First District’s decision and remanded for further proceedings consistent with Castellanos, which held that the conclusive statutory fee schedule is unconstitutional as a denial of due process under both the Florida and United States Constitutions. View "Richardson v. Aramark/Sedgwick CMS" on Justia Law

After a jury trial, Defendant was convicted of sexual battery against a child by a person eighteen years of age or older and lewd and lascivious molestation on a child by a person eighteen years of age or older. The trial court sentenced Defendant to life imprisonment plus forty years and designated him a sexual predator. The First District Court of Appeal ultimately affirmed Defendant’s sentence. The First District then certified a question to the Supreme Court asking whether case law requires preservation of an evidentiary deficiency where the State proved only a lesser included offense and the sentence required for the greater offense would be unconstitutional as applied to the lesser offense. The Supreme Court answered the certified question in the affirmative but remanded the matter on the grounds that Defendant’s trial counsel rendered ineffective assistance by failing to move for judgment of acquittal of the greater offenses during or after trial. View "Monroe v. State" on Justia Law