Justia Constitutional Law Opinion Summaries

Defendant was convicted of two counts of first degree murder, burglary and robbery. On remand, the trial court imposed a sentence of death for one of the murders. The Supreme Court affirmed. Defendant subsequently filed a motion for postconviction relief, alleging, among other things, that he was denied the effective assistance of counsel. The postconviction court granted Defendant’s motion to the extent that he was entitled to a new penalty phase trial based on ineffective assistance of counsel. The Supreme Court reversed the postconviction court’s judgment that Defendant be afforded a new penalty phase, as counsel did not provide constitutionally ineffective assistance under Strickland v. Washington, and otherwise affirmed. View "State v. Woodel" on Justia Law

Appellant and his codefendant were convicted of kidnapping and first-degree murder. Appellant was sentenced to death. After the Supreme Court affirmed Appellant’s convictions and sentence, Appellant filed a motion to vacate his judgment of conviction for murder and his death sentence and also filed a motion for DNA testing. The postconviction court denied postconviction relief and denied DNA testing. The Supreme Court affirmed, holding that the postconviction court did not err in (1) denying relief on some of Appellant’s ineffective assistance of counsel claims after an evidentiary hearing; (2) summarily denying the remainder of Appellant’s ineffective assistance of counsel claims; and (3) denying Appellant’s motion for postconviction DNA testing. View "Jackson v. State" on Justia Law

Petitioners filed a petition for extraordinary writ relief concerning certain documents in the possession of Respondents, non-parties to litigation regarding the constitutional validity of the 2012 plan apportioning Florida’s congressional districts under the Fair Districts Amendments. Petitioners contended that the documents demonstrated “the surreptitious participation of partisan operatives in the apportionment process," but the First District Court of Appeal precluded the admission of the documents. The Supreme Court granted relief to Petitioners and stayed the enforcement of the First District’s order, holding that the circuit court was not precluded from admitting the documents into evidence, subject to a proper showing of relevancy, but that the court must maintain the confidentiality of the documents by permitting disclosure or use only under seal in a courtroom closed to the public. View "League of Women Voters v. Data Targeting, Inc." on Justia Law

After a jury trial, Appellant was convicted of first-degree murder, attempted first-degree murder, grand theft of a motor vehicle, home invasion robbery, and aggravated assault on a police officer. The trial court imposed a sentence of death for the murder conviction. The Supreme Court affirmed the convictions and sentences. Appellant subsequently filed a motion to vacate his conviction and sentence of death pursuant to Fla. R. Crim. P. 3.851, presenting ten claims. The postconviction court summarily denied all claims except Appellant’s claim of ineffective assistance of counsel. After an evidentiary hearing, the postconviction court denied Appellant’s ineffective assistance of counsel claim. The Supreme Court affirmed the trial court’s order denying postconviction relief, holding (1) Appellant’s trial counsel were not ineffective; and (2) Appellant’s challenges to the death penalty in Florida were either waived, procedurally barred, meritless, or premature. View "Turner v. State" on Justia Law

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

After a jury trial, Appellant was convicted of two counts of first-degree murder. Appellant was sentenced to death for the murders. The Supreme Court affirmed the convictions and sentences. Appellant subsequently filed a motion to vacate the convictions and sentences pursuant to Fla. R. Crim. P. 3.851, asserting four claims. The postconviction court summarily denied Appellant’s motion without an evidentiary hearing. Appellant appealed the summary denial of his motion and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of the Rule 3.851 motion and denied the petition for writ of habeas corpus, holding, among other things, that (1) Appellant was afforded constitutionally effective assistance of trial counsel; (2) Appellant’s allegation of improper argument by the prosecution was procedurally barred; and (3) Appellant’s claim that to execute him would be unconstitutional because he was mentally ill was without merit. View "McKenzie v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Appellant’s convictions of first-degree murder and his sentences of death on appeal. Appellant subsequently filed a motion to vacate judgment of conviction and death sentence. After an evidentiary hearing, the circuit court denied the motion. The Supreme Court affirmed the circuit court’s denial of Appellant’s postconviction motion and denied habeas relief, holding (1) trial counsel did not render constitutionally deficient assistance by failing to object to the striking of a minority venireperson, failing to object to certain comments made by the trial court and the State, failing to file a motion to preclude the State from seeking the death penalty, and failing to investigate and present certain mitigation evidence; (2) Florida’s method of execution by lethal injection did not violate Appellant’s constitutional rights; and (3) appellate counsel was not ineffective for failing to raise on appeal the unconstitutionality of the strike of the minority venireperson. View "Frances v. State" on Justia Law

Plaintiff filed a lawsuit against Defendant, her former employer, alleging that Defendant took adverse employment actions against her after she revealed that she was pregnant. The trial court dismissed Plaintiff’s lawsuit for failure to state a cause of action. The court of appeal affirmed, concluding that Florida law does not prohibit pregnancy discrimination in employment practices. The Supreme Court quashed the court of appeal’s decision and remanded with directions that the trial court reinstate Plaintiff’s complaint, holding that the provision in the Florida Civil Rights Act (FCRA) making it an unlawful employment practice for an employer to discriminate based on an individual’s sex includes discrimination based on pregnancy, which is “a natural condition and primary characteristic unique to the female sex.” View "Delva v. Continental Group, Inc. " on Justia Law

After a jury trial, Defendant was convicted of sexual battery for penetrating the victim’s vagina with his penis and lewd or lascivious molestation for intentionally touching the victim’s breasts, genitals, genital area, buttocks, or the clothing covering them. On appeal, the Second District Court of Appeal reversed and remanded for the trial court to vacate Defendant’s conviction for lewd or lascivious molestation, concluding that double jeopardy prohibited convictions for both sexual battery and lewd or lascivious molestation in a single criminal episode. The Supreme Court quashed the decision of the Second District and remanded to the district court for an order affirming Defendant’s convictions, holding that Defendant’s convictions involved offenses of a separate character and type, which were distinct criminal acts that do no violate double jeopardy. View "State v. Drawdy" on Justia Law

In 1995, Petitioner was convicted of first-degree felony murder, aggravated child abuse, and sexual battery. The jury recommended the death penalty, and the trial court imposed the death penalty. The Supreme Court affirmed on appeal. In 2006, Petitioner filed a third amended motion to vacate the judgments of convictions and sentences, asserting fourteen claims of error. After an evidentiary hearing, the postconviction court denied Petitioner’s motion for postconviction relief. The Supreme Court affirmed the postconviction court’s denial of Petitioner’s motion for postconviction relief and denied his petition for a writ of habeas corpus, holding (1) Petitioner failed to establish that the State violated Brady v. Maryland and Giglio v. United States; and (2) Petitioner’s trial counsel did not provide ineffective assistance. View "Davis v. State" on Justia Law