Justia Constitutional Law Opinion Summaries

Defendant was convicted of first-degree murder, kidnapping, and sexual battery with great force. Defendant was sentenced to death. The Supreme Court affirmed Defendant’s convictions and sentence of death. Defendant subsequently filed a motion for postconviction relief, raising several allegations of error. The postconviction court denied the motion. The Supreme Court affirmed the postconviction court’s denial of relief and denied Defendant’s petition for a writ of habeas corpus, holding (1) trial counsel did not provide ineffective assistance; (2) Defendant was not entitled to relief on his claims relating to the State’s alleged use of Defendant’s co-defendant as a state agent and letters written between the co-defendant and Defendant; and (3) appellate counsel did not provide ineffective assistance. View "Johnson v. State" on Justia Law

In 1980, Appellant was convicted of first-degree murder and sentenced to death. After the Governor signed the death warrant in this case, Appellant filed a successive motion for postconviction relief seeking to vacate his judgments of conviction and sentence of death. Appellant also filed motions for disclosure of public records, discovery, and for a stay. The circuit court summarily denied the motions and postconviction claims. The Supreme Court temporarily relinquished jurisdiction for the purpose of holding an evidentiary hearing on the sole issue of the safety and efficacy of the new drug in the lethal injection procedure. After an evidentiary hearing, the circuit court rejected the claim that the use of midazolam hydrochloride as the first drug in the three-drug lethal injection protocol would result in a substantial risk of serious harm and, accordingly, held that the protocol was constitutional. The Supreme Court (1) affirmed the circuit court's order denying postconviction relief on the claims raised in Appellant's successive postconviction motion; but (2) reversed the circuit court's order denying Appellant's public records request for copies of his own inmate and medical records and ordered transmission of copies of those records to Appellant's counsel. View "Muhammad v. State" on Justia Law

Defendant pled guilty to first-degree murder with a firearm. After a penalty-phase proceeding conducted before a jury, the trial court imposed the death sentence for the murder. The Supreme Court affirmed the conviction and sentence of death, holding (1) the trial court did not abuse its discretion in finding and assigning great weight to a cold, calculated, and premeditated (CCP) aggravator; (2) Defendant's death sentence was a proportionate punishment in this case; (3) Defendant failed to present any compelling reason for the Court to reconsider its established precedent on the issue of whether a mental illness rendered Defendant's execution unconstitutional; and (4) Defendant's guilty plea was knowingly, intelligently, and voluntarily entered. View "McCoy v. State" on Justia Law

Plaintiffs brought lawsuits challenging the validity of the 2012 congressional apportionment plan (Plan) under the Florida Constitution's redistricting standards. At issue before the Supreme Court was whether Florida state legislators and legislative staff members had an absolute privilege against testifying as to issues directly relevant to whether the Legislature drew the Plan with unconstitutional partisan or discriminatory intent. The circuit court permitted the discovery of information and communications, including the testimony of legislators, pertaining to the constitutional validity of the Plan. The court of appeal reversed, holding that the legislators had the absolute protection of a legislative privilege. The Supreme Court quashed the court of appeal's decision and approved the circuit court's order, holding (1) Florida recognizes a legislative privilege founded on the constitutional principle of separation of powers; but (2) this privilege is not absolute where, as in this case, the purposes underlying the privilege are outweighed by the compelling, competing interest of effectuating the explicit constitutional mandate that prohibits partisan political gerrymandering and improper discriminatory intent in redistricting. View "League of Women Voters of Fla. v. Fla. House of Representatives" on Justia Law

Defendant was convicted of robbing and killing Johnny Parrish and burning down Parrish's house. The trial court sentenced Defendant to death for the first-degree murder conviction. Defendant subsequently filed two postconviction motions and two additional petitions for a writ of habeas corpus, all of which were denied. Defendant then instituted this second successive postconviction motion, raising three claims. After an evidentiary hearing, the postconviction court denied relief. The Supreme Court affirmed, holding (1) Defendant failed to meet his burden to demonstrate that the State knowingly presented false or misleading evidence that it failed to correct at Defendant's trial in violation of Giglio v. United States; and (2) Defendant failed to show that newly discovered evidence was of "such a nature that it would probably produce an acquittal on retrial." View "Moore v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed the conviction and sentence on appeal. Appellant subsequently filed a postconviction motion seeking to vacate his conviction and sentence as well as a motion seeking a ruling that he was ineligible to be executed due to mental retardation. The postconviction court denied both motions. Appellant appealed the denial of his motions and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the postconviction court's orders and denied Appellant's habeas petition, holding (1) Appellant was not entitled to relief on any of his claims raised in his motion for postconviction relief; (2) Appellant was not entitled to relief on his mental retardation-related claims; and (3) Appellant's habeas claims were not properly presented in a petition for a writ of habeas corpus, and thus, Appellant was not entitled to habeas corpus relief. View "Diaz v. State" on Justia Law

After a jury trial in 1985, Appellant was convicted of first-degree murder and sexual battery. Appellant later filed a motion for postconviction relief seeking to have his convictions vacated after newly discovered evidence revealed that there was no seminal fluid found in the victim. At the time of Appellant's trial, the Florida law enforcement department tested vaginal and anal swabs of the victim and got a positive result for acid phosphatase (AP). The AP evidence was crucial to the State's case that a sexual battery occurred especially since the victim was found fully clothed and the medical examiner relied on the now-discredited testing that AP was present in order to conclude the victim was sexually battered. The newly discovered evidence also impacted the first-degree murder conviction because without evidence that a sexual battery occurred, the evidence linking Appellant to the murder was scant. The circuit court denied relief. The Supreme Court reversed and vacated Appellant's convictions and sentences, holding that the newly discovered evidence weakened the case against Appellant so as to give rise to a reasonable doubt as to his culpability. Remanded for a new trial. View "Swafford v. State" on Justia Law

After a jury trial, Petitioner was convicted of the first-degree murders of his two stepdaughters. The trial court sentenced Petitioner to death for each of the murders. The Supreme Court affirmed Petitioner's convictions and sentences on appeal. The Office of Capital Collateral Regional Counsel filed Petitioner's initial postconviction motion, but Petitioner refused to sign the required verification of the motion. After granting extensions of time and giving Petitioner numerous opportunities to file a verified motion, the trial court dismissed the unverified postconviction motion with prejudice. Petitioner appealed and also filed a petition for writ of habeas corpus claiming that the trial court erred in allowing him to proceed pro se at trial. The Supreme Court affirmed, holding (1) the trial court did not err in determining that Petitioner was competent to proceed with postconviction litigation; (2) the trial court did not err in dismissing Petitioner's postconviction motion with prejudice for failing to file a facially sufficient motion; and (3) Petitioner's petition for habeas corpus as relief was not warranted. View "Hernandez-Alberto v. Crews" on Justia Law

Two women, DMT and TMH, agreed to jointly conceive and raise a child together. The child was conceived through the use of assisted reproductive technology. TMH provided the egg, and DMT gave birth to the child. The couple participated in raising their child together until their relationship ended and DMT absconded with the child. TMH sought to establish her parental rights to the child and to reassume parental responsibilities. The court of appeal concluded that Florida's assisted reproductive technology statute was unconstitutional as applied to TMH because it automatically deprived TMH of her ability to assert her fundamental right to be a parent. The Supreme Court affirmed, concluding that, based on the circumstances of this case, the statute was unconstitutional as applied to abridge TMH's fundamental right to be a parent and violated state and federal equal protection by denying same-sex couples the statutory protection against the automatic relinquishment of parental rights that it affords to heterosexual unmarried couples seeking to utilize the assistance of reproductive technology. Remanded. View "D.M.T. v. T.M.H." on Justia Law

Appellant was convicted of first-degree murder, burglary of a battery therein, and sexual battery with great force. Appellant was sentenced to death. The Supreme Court upheld the convictions and death sentence on appeal and later upheld the denial of postconviction relief and denied habeas relief. After Appellant was scheduled for execution, he filed a successive postconviction motion, claiming that Florida's death penalty statute violated the Eighth Amendment because most states require a unanimous jury verdict to recommend a death sentence and because alleged newly discovered evidence revealed that the number of defendants sentenced to death in Florida increased in 2012 compared to the rest of the nation. The circuit court denied relief. The Supreme Court affirmed, holding (1) non-unanimous jury recommendations to impose the sentence of death are not unconstitutional; and (2) the circuit court accurately found that the studies cited by Appellant in support of his second claim did not qualify as newly discovered evidence. View "Kimbrough v. State" on Justia Law