Justia Constitutional Law Opinion Summaries

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 $13.28 per hour for 120 hours of work, over twenty-five times less than the $350 hourly rate found to be a reasonable fee. The First District Court of Appeal was compelled to affirm the fee. 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 "Diaz v. Palmetto Gen. Hosp." on Justia Law

Petitioner, who was injured in the course of his employment with Respondent, prevailed in his workers’ compensation claim through the assistance of his attorney. The fee awarded to Petitioner’s attorney amounted to only $1.53 per hour. Petitioner had no ability to challenge the reasonableness of the hourly rate, and both the Judge of Compensation Claims and First District Court of Appeal were precluded by Fla. Stat. 440.34, which mandates a conclusive fee schedule for awarding attorney’s fees to the claimant in a workers’ compensation case, from assessing whether the fee award was reasonable. The First Circuit certified a question to the Supreme Court regarding the constitutionality of section 440.34, which creates an irrebuttable presumption that precludes any consideration of whether the fee award is reasonable to compensate the attorney. The Supreme Court held that the mandatory fee schedule in section 440.34 is unconstitutional under as a violation of due process under both the state and federal Constitutions. Remanded for entry of a reasonable attorney’s fee. View "Castellanos v. Next Door Co." on Justia Law

Defendant was convicted of two counts of first-degree murder and sentenced to death for the murders. Defendant filed a motion to vacate his convictions and sentences, arguing that he was denied a fair guilt phase because of counsel’s deficient performance and that he was denied a fair penalty phase because counsel provided ineffective assistance. After an evidentiary hearing, the circuit court denied relief on all claims. The Supreme Court affirmed the postconviction court’s order denying postconviction relief on all claims, holding that Defendant’s counsel provided constitutionally effective assistance during both the guilt phase and the penalty phase. View "Rigterink v. State" on Justia Law

Defendant was indicted on two counts of first-degree murder. Defendant moved to suppress any statements he made to law enforcement and any evidence obtained as a result of those statements, asserting that he was in custody when he was questioned and was not read the Miranda warnings and that he was improperly denied access to his attorney. The trial court denied the motion to suppress. The Second District Court of Appeal reversed, holding (1) Defendant was not in custody when he initially confessed to the murders, but (2) once Defendant confessed and was read the Miranda warnings, he was in custody and should have been informed that the attorney retained on his behalf was at the sheriff’s office where Defendant was being interrogated and was available to speak to Defendant. The Supreme Court quashed the Second District’s decision and remanded, holding (1) when a person is questioned in a non-public location and an attorney retained on his behalf appears at the location, due process requires that law enforcement notify the person with regard to the presence and purpose of the attorney, regardless of whether the person is in custody; and (2) the Miranda violation in this case constituted harmful error. View "State v. McAdams" on Justia Law

June Dhar was a short-term renter of an automobile that was detected by an automated traffic camera running a red light. The vehicle was registered to Dollar Rent A Car Systems, Inc. Dollar was sent a notice of violation. Dollar responded by sending an affidavit identifying Dhar as the person having control of the vehicle at the time of the violation. Thereafter, Dhar was issued a uniform traffic citation. Dhar filed a motion to dismiss, arguing that as a short-term renter of the motor vehicle she was treated unequally because she was not initially issued a notice of citation under Fla. Stat. 316.0083(1)(b)1.a and therefore could not avoid the payment of added court costs by paying the statutory penalty of $158. The trial court granted Dhar’s motion, concluding that the unequal treatment of short-term renters violated equal protection. The court of appeal affirmed the lower court’s order granting Dhar’s motion to dismiss. The Supreme Court affirmed, holding that Fla. Stat. 316.0083 is unconstitutional as applied to short-term vehicle renters such as Dhar. View "City of Fort Lauderdale v. Dhar" on Justia Law

Defendant was convicted of both sexual battery on a person under twelve years of age and lewd or lascivious molestation on a person under twelve years of age for a single act. Defendant appealed, arguing that his dual convictions violated his constitutional protection against double jeopardy. The court of appeal concluded that convictions for both lewd or lascivious molestation and sexual battery arising from the same act do not violate the constitutional prohibition against double jeopardy. The Supreme Court affirmed, holding that Defendant’s separate sentences for capital sexual battery and lewd or lascivious molestation arising from a single act do not violate the prohibition against double jeopardy. View "Roughton v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder, attempted first-degree murder, and related crimes. The trial court sentenced Defendant to death. The Supreme Court affirmed the conviction and death sentence. Appellant later filed a motion for postconviction relief, which the trial judge denied. Appellant appealed and also petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court remanded for a new penalty phase and denied Appellant’s habeas petition, holding (1) trial counsel was ineffective for failing to investigate and present mitigation, including Appellant’s background and intellectual functioning, at the penalty phase; and (2) Appellant’s claims in his habeas petition were unavailing. View "Salazar v. State" on Justia Law

Appellant was found guilty of the first-degree murder and aggravated child abuse of her three-year-old son, Lazaro. The Supreme Court vacated Appellant’s convictions and remanded for a new trial, holding that the pervasiveness and the cumulative effect of the prosecutor’s multiple improper closing arguments in the guilt phase, which repeatedly invoked “justice for Lazaro” and appealed to the passions of the jury, constituted impermissible prosecutorial misconduct and deprived Appellant of a fair trial. Moreover, most of the improper comments were objected to, and those objections were overruled by the trial court, increasing the prejudicial effect of the comments. View "Cardona v. State" on Justia Law

Tyron Francois, a Democrat, filed paperwork to run as a write-in candidate for Broward County Commission for District 2. A resident voter filed a complaint alleging that Francois was not properly qualified to be a write-in candidate because he did not physically live within the boundaries of the district as required by Fla. Stat. 99.0615. In response, Francois argued that section 99.0615 is facially unconstitutional. The circuit court found that section 99.0615 is constitutional and disqualified Francois as a write-in candidate. The Fourth District Court of Appeal reversed, concluding that the statute is facially unconstitutional because the timing of its residency requirement for write-in candidates conflicts with the timing of the residency requirement for county commission candidates as established by Fla. Const. art. VIII, 1(e). The Supreme Court affirmed, holding (1) section 99.0615 contravenes the residency requirement applicable to county commissioners under Fla. Const. art. VIII, 1(e), and thus Francois properly qualified as a write-in candidate; and (2) write-in candidates are included within the intended meaning of “opposition” as used in a different constitutional provision, and therefore, it was appropriate for the Democratic Party’s primary election to be closed to only Democratic-registered voters. View "Brinkmann v. Francois" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder. Defendant was sentenced to death. The Supreme Court affirmed. Defendant subsequently filed a motion for postconviction relief, alleging ineffective assistance of trial counsel, due process violations, and a claim under Ring v. Arizona. The trial court denied postconviction relief. Defendant appealed the denial of relief and also filed a petition for a writ of habeas corpus and for extraordinary relief. The Supreme Court reversed the trial court’s denial of postconviction relief, holding that Defendant’s counsel provided ineffective assistance to the prejudice of Defendant. Remanded for a new trial. View "Ibar v. State" on Justia Law