Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of three counts of sexual battery and one count each of kidnapping, aggravated battery, and attempted robbery. Defendant was sentenced to life imprisonment for each sexual battery count and the kidnapping count. Defendant appealed, arguing that the trial court abused its discretion in refusing to give a curative instruction relating to statements the prosecutor made during voir dire. The Second District Court of Appeals found that the prosecutor’s remarks were improper but that there was “no reasonable possibility that the failure to give a curative instruction affected the verdict.” The Supreme Court quashed the Second District’s decision, holding that the prosecutor impermissibly commended during voir dire on Defendant’s constitutional right to remain silent, and the comments were not harmless beyond a reasonable doubt. View "Marston v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder, armed robbery with a deadly weapon, and arson. Appellant was sentenced to death for the murders. Appellant’s death warrant was signed and his execution set for March 20, 2014. Appellant filed several post-trial motions, all of which were denied. In this appeal, Appellant challenged the denial of his second successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, his motion to declare Fla. Stat. 922.052 unconstitutional, and his motion to dismiss his death warrant. The Supreme Court affirmed the postconviction court’s denial of relief on all three motions and denied Appellant’s motion for a stay of execution, holding that the postconviction court did not err in its judgment. View "Henry v. State" on Justia Law

Michelle McCall received prenatal medical care at a United States Air Force clinic as an Air Force dependent. McCall died after delivering her son as a result of severe blood loss. Petitioners filed an action against the United States under the Federal Tort Claims Act (FTCA). The federal district court found the United States liable under the FTCA. The court concluded that Petitioners’ economic damages amounted to $980,462 and Petitioners’ noneconomic damages totaled $2 million. However, the district court limited Petitioners’ recovery of wrongful death noneconomic damages to $1 million after applying Fla. Stat. 766.118, Florida’s statutory cap on wrongful death noneconomic damages based on medical malpractice claims. The district court subsequently denied Petitioners’ motion challenging the constitutionality of the wrongful death statutory cap. The Eleventh Circuit Court of Appeals affirmed the application of the statutory cap on noneconomic damages and held that the statute was not unconstitutional. The Florida Supreme Court accepted certification to answer questions of Florida law and answered by holding the statutory cap on wrongful death noneconomic damages provided in Fla. Stat. 766.118 violates the Equal Protection Clause of the Florida Constitution. View "Estate of McCall v. United States" on Justia Law

Appellant was convicted of first-degree murder and sentenced to death for killing a Florida Highway Patrol Trooper. The Governor set a death warrant for Appellant and scheduled his execution for February 26, 2014. This appeal concerned the denial of Appellant’s amended third successive motion for postconviction relief in which he challenged the Florida lethal injection protocol as applied to him. The Supreme Court affirmed the postconviction court’s denial of relief, holding (1) Appellant's suggestion that the Court depart from its established precedent as to the proper standard to apply to an Eighth Amendment challenge to the lethal injection protocol was unavailing; (2) the use of midazolam hydrochloride in the 2013 lethal injection protocol does not violate the Eighth Amendment; (3) the forced administration of vecuronium bromide does not violate Appellant’s Fourteenth Amendment rights under Sell v. United States because the holding of Sell does not apply to these circumstances; and (4) the postconviction court did not err in denying Appellant’s request to strike a witness’s testimony. View "Howell v. State " on Justia Law

After a jury trial, Appellant was convicted of the first-degree murder, kidnapping, and sexual battery of a nine-year-old and sentenced to death. After the Governor signed the warrant in this case Appellant filed numerous public records requests, a second successive motion for postconviction relief, and a request for a stay of execution. The circuit court denied Appellant's public records requests, his postconviction petition, and his request for a stay of execution. The Supreme Court affirmed in all respects, holding that the circuit court did not err in its rulings. View "Chavez v. State" on Justia Law

After a second jury trial, Appellant was convicted of first-degree murder and robbery and was sentenced to death. The Supreme Court affirmed the convictions but twice remanded for new penalty phases. Each time, the trial court sentenced Defendant to death. The Supreme Court affirmed the sentence of death. Appellant subsequently moved to vacate judgment of convictions and sentences, alleging ineffective assistance of counsel. The postconviction court denied all claims presented in Appellant’s motion to vacate. The Supreme Court affirmed, holding that the postconviction court did not err in denying Appellant’s claims of ineffective assistance of counsel during his second guilt phase trial and during his fourth penalty phase trial. View "Lebron v. State" on Justia Law

Plaintiff filed a medical malpractice wrongful death action against Cedars Healthcare Group, a facility at which Plaintiff’s father was a patient when he died, and other health care providers. Plaintiff sought records of adverse medical incidents from Cedars pursuant to Fla. Const. art. X, 25, which guarantees patients the right to “have access to any records made or received in the course of business by a health care facility or provider relating to any adverse medical incident.” The trial court overruled Cedars’ objection to the discovery request. Cedars subsequently petitioned the district court for a writ of certiorari. Citing to Fla. Stat. 381.028(7)(a), the district court granted the petition on the ground that the request to produce asked for “records of adverse medical incidents involving patients other than the plaintiff” but did not limit the production of those records to the same or substantially similar condition as the patient requesting access. Prior to the district court’s decision, the Supreme Court, in Florida Hospital Waterman, Inc. v. Buster, declared section 381.028(7)(a) invalid. Accordingly, the Court quashed the decision of the district court in this case and remanded for reconsideration pursuant to Buster. View "Ampuero-Martinez v. Cedars Healthcare Group" on Justia Law

The Florida Attorney General petitioned the Supreme Court for an advisory opinion as to the validity of a proposed citizen initiative amendment to the Florida Constitution and the accompanying Financial Impact Statement. Upon review, the Supreme Court approved the proposed amendment and Financial Impact Statement for placement on the ballot, concluding (1) the proposed amendment satisfies the single-subject requirement of Fla. Const. art. XI, 3 because it embraces a single subject, which is the medical use of marijuana; (2) the ballot title and summary comply with the clarity requirements of Fla. Stat. 101.161(1) because they give voters fair notice as to the chief purpose and scope of the proposed amendment and will not affirmatively mislead voters regarding the purpose of the proposed amendment; and (3) the Financial Impact Statement complies with Fla. Stat. 100.371(5). View "Advisory Opinion to the Attorney General Re Use of Marijuana for Certain Medical Conditions" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder under the felony murder and premeditated theories in the deaths of Berthum Gibson and Keenethia Keenan and guilty of first-degree murder under the felony murder theory in the death of Desmond Robinson. Defendant was sentenced to death for the deaths of Gibson and Keenan. The Supreme Court affirmed the convictions and sentences, holding (1) the evidence was sufficient to support Defendant’s convictions under both the felony murder and premeditation theories; (2) the trial court did not err in giving additional weight to the felony murder aggravating circumstance; (3) Defendant’s death sentences were proportional; and (4) Defendant’s death sentences were not unconstitutional under Ring v. Arizona. View "Smith v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed on direct appeal. Defendant subsequently filed an amended motion to vacate his judgment and sentence, which the postconviction court denied. Defendant appealed and filed an accompanying petition for writ of habeas corpus. The Supreme Court affirmed, holding (1) the postconviction court did not err in finding Defendant competent to proceed in his postconviction proceedings; (2) the postconviction court did not err in denying Defendant’s claim of ineffective assistance of trial counsel during the penalty phase and voir dire; (3) the postconviction court did not err in summarily denying Defendant’s claim that trial counsel was ineffective for failing to file a motion for a change of venue; (4) Florida’s method of execution for lethal injection is constitutional; and (5) Defendant was not entitled to relief on his claim that his right against cruel and unusual punishment would be violated because he may be incompetent at the time of execution. View "Franklin v. State" on Justia Law