Justia Constitutional Law Opinion Summaries

Articles Posted in Florida Supreme Court
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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

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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

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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

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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

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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

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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

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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

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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

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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

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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