Justia Constitutional Law Opinion Summaries

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

After a jury trial, Appellant was convicted of the kidnapping, capital sexual battery, and first-degree murder of an eleven-year-old girl. The trial court sentenced Appellant to death for the murder. The Supreme Court affirmed Appellant’s convictions and sentences on appeal. Appellant subsequently filed a motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, presenting several claims. The postconviction court summarily denied all claims. The Supreme Court affirmed, holding (1) Appellant’s argument that criminal defense counsel should have unlimited authority to conduct interviews to probe jurors for possible misconduct was without merit; (2) the postconviction court properly denied Appellant’s claims that the trial court improperly instructed the jury regarding its role; (3) the postconviction court did not err when it held that Florida’s capital sentencing statute is not unconstitutional; and (4) Appellant’s challenge to the constitutionality of Florida’s lethal injection procedures was without merit. View "Smith v. State" on Justia Law

In Sirota v. State, the court of appeal certified a question to the Supreme Court regarding the scope and proper application of the Court’s decision in Morgan v. State. Thereafter, the Supreme Court decided Alcorn v. State, wherein the Court receded from Morgan with respect to the standard for establishing prejudice as to ineffective assistance of counsel claims in which the defendant rejected a plea offer based on misadvice. After Alcorn became final, the Court issued an order directing the defendant below to show cause why the Court should not summarily quash the court of appeal’s decision in Sirota and remand for reconsideration in light of Alcorn. After the parties responded, the Supreme Court quashed the court of appeal’s decision in Sirota and remanded for further proceedings consistent with the Court’s decision in Alcorn. View "State v. Sirota" on Justia Law

Appellant was convicted and sentenced to death for the first-degree murder of Monquell Wimberly. Appellant was also convicted of the first-degree felony murder of Patrick Stafford, for which Stafford was sentenced to life imprisonment. The Supreme Court affirmed Appellant’s convictions and sentence of death, holding (1) there was no fundamental error in the admission of a videotaped statement Appellant gave to detectives after he was taken into custody; (2) there was no prejudicial error in the admission of a codefendant’s out-of-court statement; (3) the admission of testimony concerning an eyewitness’s fear of the shoot did not constitute fundamental error; (4) Appellant was not entitled to relief on his claim of juror misconduct or premature deliberation; and (5) competent, substantial evidence supported the verdict of guilt as to the first-degree murder conviction and the felony murder conviction. View "Sheppard v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder and one count of armed carjacking. The trial court sentenced Appellant to death. The Supreme Court affirmed Appellant’s convictions and sentences on appeal. Appellant subsequently filed a motion for postconviction relief, raising twenty-eight claims. After an evidentiary hearing on several of those claims, the circuit court denied relief. Appellant appealed, raising twenty-one claims, and also filed a habeas petition raising two claims of ineffective assistance of appellate counsel. The Supreme Court (1) affirmed the postconviction court’s order denying relief on all postconviction claims, holding that Appellant failed to establish that any errors occurred which, either individually or cumulatively, would entitle him to a new trial; and (2) denied relief on both claims Appellant raised in his petition for writ of habeas corpus, as both claims were procedurally barred. View "Deparvine v. State" on Justia Law

Appellant was convicted of first-degree murder in the shooting death of a law enforcement officer, which occurred after the officer stopped Appellant for a traffic infraction. The jury recommended that the death penalty be imposed, and the circuit court sentenced Appellant to death. Appellant filed an amended motion for postconviction relief pursuant to Fla. R. Crim. P. 3.851, alleging that his trial counsel provided ineffective assistance. The court below denied the motion in a final order. The Supreme Court affirmed, holding that Appellant failed to satisfy the Washington v. Strickland standard in the postconviction proceeding held below. View "Bailey v. State" on Justia Law