Justia Constitutional Law Opinion Summaries

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

Appellant was indicted on charges of two counts of first-degree premeditated murder. Appellant entered written and oral guilty pleas to all charges. Appellant subsequently waived his right to a penalty phase jury and his right to be present in the penalty phase. Appellant was sentenced to death for the murders. The Supreme Court affirmed the trial court’s judgment. Appellant later filed a motion for postconviction relief, alleging ineffective assistance of counsel, among other claims. The circuit judge denied all claims. The Supreme Court affirmed, thus denying Appellant’s claims that trial counsel provided constitutionally ineffective assistance and Appellant’s challenges to the constitutionality of several of Florida’s death penalty provisions. View "Allred v. State" on Justia Law

Lucious Boyd was convicted of first-degree murder and sentenced to death. Boyd filed a motion to vacate his conviction and sentence. The circuit court denied relief. Boyd appealed the circuit court’s order denying postconviction relief and also petitioned for a writ of habeas corpus. As to Boyd’s postconviction relief claims, the Supreme Court held (1) Boyd failed to show that he was entitled to a new trial on his claims of actual juror bias; and (2) Boyd was not entitled to relief on his ineffective assistance of counsel claims. The Court also denied Boyd’s petition for writ of habeas corpus. View "Boyd v. State" on Justia Law

Defendant was convicted and sentenced to death for the first-degree murder of an eleven-year-old girl. The Supreme Court affirmed the conviction and sentence. This appeal concerned Defendant’s amended successive Fla. R. Crim. P. 3.850 motion in which Defendant alleged four claims. The trial court summarily denied all claims. The Supreme Court affirmed the denial of one claim but remanded for an evidentiary hearing on the remaining claims. On remand, the trial court again denied all claims. The Supreme Court affirmed, holding (1) Defendant failed to establish a Giglio violation; (2) Defendant failed to establish a Brady violation, and Defendant’s ineffective assistance of trial counsel claim, pled as an alternative to his Brady claim, was procedurally barred; and (3) because newly discovered DNA evidence was not of such a nature that it would probably produce an acquittal on retrial, relief on Defendant’s newly discovered DNA evidence claim was properly denied. View "Rivera v. State" on Justia Law

Tai Pham was convicted of first-degree murder, attempted first-degree murder, armed kidnapping, and armed burglary. The trial court entered a sentence of death. The Supreme Court affirmed the convictions and sentences. Pham later filed a motion to vacate judgment of conviction and sentence of death, raising several claims. The circuit court summarily denied some claims and held an evidentiary hearing on the remaining claims. Thereafter, the court denied relief. Pham appealed and also filed a petition for a writ of habeas corpus. The Supreme Court affirmed, holding (1) Pham failed to establish that he received ineffective assistance of counsel during either the guilt or the penalty phase; and (2) appellate counsel likewise did not provide ineffective assistance. View "Pham v. State" on Justia Law

Petitioner was convicted of four counts of armed sexual battery and ultimately sentenced to four life sentences as upward departure sentences. The second district affirmed Petitioner’s four life sentences. Petitioner later filed a motion to correct illegal sentence under Fla. R. Crim. P. 3.800(a), claiming that under Apprendi v. New Jersey and Blakely v. Washington he was entitled to a jury trial at his resentencing to determine the factual basis for the upward departure. The circuit court denied the motion, finding that Petitioner’s sentences were within their statutory maximums. The Second District affirmed, concluding that Petitioner’s claim of Apprendi error was not a ground for relief under rule 3.800(a) because it was not preserved and raised on direct appeal. The Supreme Court quashed the Second District’s decision and remanded to the district court for the application of a harmless error analysis, holding that Petitioner’s four life sentences were unconstitutionally enhanced under Apprendi and Blakely, and therefore, the sentences were illegal under rule 3.800(a). View "Plott v. State" on Justia Law