Justia Constitutional Law Opinion Summaries

Appellant was convicted of two counts of first-degree murder. The trial court imposed two death sentences after finding several aggravating factors. The Supreme Court affirmed on direct appeal. After Appellant's initial motion for postconviction relief was denied, Appellant filed a motion for DNA testing, which was also denied. Appellant subsequently filed in federal court a petition for a writ of habeas corpus, which was denied. Appellant then filed a successive postconviction motion, claiming that the American Society of Addiction Medicine (ASAM) Public Policy Statement defining addiction as a brain disorder was newly discovered evidence which, if presented to a jury, would probably result in a life sentence. The circuit court summarily denied the claim. The Supreme Court affirmed, holding that the ASAM definition was not newly discovered evidence, and even if the ASAM policy statement was considered to be newly discovered evidence and it was admitted at trial, it was not probable Appellant would receive a life sentence. View "Henry v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and kidnapping and sentenced to death. Appellant appealed, arguing, among other things, that (1) the trial court erred in allowing the State to ask a law enforcement officer about statements Appellant made to him during an interview without admitting the entire interview under the rule of completeness; and (2) the trial court erred in finding the avoiding arrest and cold, calculated, and premeditated (CCP) aggravators. The Supreme Court affirmed, holding (1) Appellant failed to properly preserve his first claim, and even if he had, any error in not admitting the statements under the rule of completeness was harmless beyond a reasonable doubt; (2) the trial court erred in finding the avoiding arrest aggravator, but this error was harmless, and there was competent, substantial evidence to support the finding of CCP; (3) there was sufficient evidence to support Appellant's convictions; and (4) the death sentence was proportional in this case. View "Calhoun v. State" on Justia Law

In 1986, Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed on appeal. Defendant subsequently filed a motion for postconviction relief, which the trial court denied after an evidentiary hearing. The Supreme Court remanded for a new evidentiary hearing. After a new evidentiary hearing was held in 2010, the circuit court denied postconviction relief on all claims. Defendant appealed the denial of his postconviction motion and petitioned for a writ of habeas corpus. The Supreme Court affirmed the denial of Defendant's postconviction petition and denied Defendant's petition for habeas corpus, holding (1) the circuit court did not err in denying Defendant's postconviction claims on the basis that they were either procedurally barred, refuted by the record, or otherwise without merit; and (2) Defendant did not show he was entitled to habeas relief where he failed to demonstrate either deficient performance on the part of his appellate counsel or prejudice. View "Wickham v. State" on Justia Law

Defendant pled guilty to carrying a concealed firearm and possession of a firearm by a convicted felon. Defendant appealed, arguing that the trial court erred by denying his motion to suppress the firearm, his identity as a convicted felon, and statement he made after he was detained by the police. In particular, Defendant alleged that the arresting officer lacked reasonable suspicion to conduct the Terry stop because no facts were presented to indicate that Defendant did not possess a license to carry the firearm. The court of appeal affirmed but certified conflict with Regalado v. State on the issue of whether an officer who believes that someone is carrying a concealed firearm, without more, has reasonable suspicion to conduct a Terry stop. The Supreme Court affirmed, holding (1) given the differing factual circumstances that preceded the stops in Regalado and in this case, no actual conflict existed; and (2) the court of appeal did not err in finding that the Terry stop of Defendant was valid. View "Mackey v. State" on Justia Law

Defendant was convicted of two counts of first-degree murder, two counts of attempted first-degree murder, and burglary of a dwelling. The trial court imposed death sentences for the murders of both victims. Defendant appealed, raising several issues with regard to the penalty phase that led to the imposition of the death sentences. The Supreme Court affirmed Defendant's convictions and sentences, holding (1) any error in the trial court's finding of the aggravating factors was harmless beyond a reasonable doubt; (2) the trial court did not err in allowing victim impact statements or in admitting photographs of the murder victims; (3) the imposition of the death penalty in this case was proportionate and supported by the applicable aggravating and mitigating factors; and (4) sufficient evidence in the record supported Defendant's convictions. View "Kalisz v. State" on Justia Law

After a jury trial, Defendant was convicted of trafficking in cocaine. Defendant appealed, arguing that the trial court erred by denying his motion for judgment of acquittal on the trafficking charge because the State had not chemically tested each baggie in Defendant's possession for cocaine before commingling and weighing the baggies' contents. The court of appeal affirmed, concluding that the contents of the nine individually wrapped baggies were properly commingled before they were chemically tested and weighed due to the particular circumstances that surrounded the discovery of the bags. The Supreme Court quashed the decision below, holding (1) in cases such as this one, the State must prove through chemical testing that each individually wrapped packet of white powder seized contains at least a mixture of a controlled substance before the State may combine and weigh the commingled substance; and (2) therefore, the trial court in this case should have granted Defendant's motion for judgment of acquittal. Remanded. View "Greenwade v. State" on Justia Law

After a jury trial, Defendant was convicted of the first-degree murder of a high school band teacher. The trial court sentenced Defendant to death. The Supreme Court affirmed on appeal. Defendant later filed a petition for postconviction relief under Fla. R. Crim. P. 3.850, alleging, inter alia, that his trial counsel was ineffective for several reasons. After an evidentiary hearing, the circuit court denied relief. The Supreme Court affirmed the denial of Defendant's motion for postconviction relief, holding (1) the circuit court did not prejudicially err in finding that Defendant's counsel provided effective assistance; and (2) the circuit court did not prejudicially err in summarily denying the remainder of Defendant's claims. View "Foster v. State" on Justia Law

Pursuant to a plea of nolo contendere, Defendant was convicted of sex-related offenses and sentenced to forty-five years' imprisonment. Nearly eleven years after the sentence had been imposed, Defendant filed a motion to withdraw plea arguing that he was entitled to withdraw his plea because the trial court failed formally to accept his plea during the plea colloquy. The postconviction court ruled that the trial court's inadvertent failure to formally accept Defendant's plea did not entitle Defendant to withdraw his plea. The court of appeal affirmed, holding that Defendant was not entitled to withdraw his plea after he was sentenced absent a showing of manifest injustice or clear prejudice. The Supreme Court affirmed, holding that the actual sentencing of a defendant is a sufficient affirmative statement to the parties made in open court and on the record as to constitute formal acceptance of a plea under Fla. R. Crim. P. 3.172(g), and actual sentencing evidences the finality in the proceedings where the right to withdraw a plea is revoked. View "Campbell v. State" on Justia Law

In 1988, Defendant pleaded guilty to first-degree murder. Defendant was sentenced to death and to terms of imprisonment for related charges. The Supreme Court affirmed the convictions and sentence. Defendant subsequently filed a motion to vacate his conviction for first-degree murder and sentence of death, alleging that his standby counsel or the trial court sua sponte should have ordered a competency hearing before allowing him to plead guilty and that he may be insane at the time of execution. The circuit court denied the motion without an evidentiary hearing. The Supreme Court affirmed, holding that the circuit court did not err in summarily denying Defendant's motion for postconviction relief from his conviction and sentence for first-degree murder. View "Barnes v. State" on Justia Law

After a jury trial, Defendant was convicted of six counts of first-degree murder and one count each of abuse to a dead human body, armed burglary of a dwelling, conspiracy, and cruelty to an animal. The trial court imposed four death sentences, two life sentences, and additional terms for the noncapital crimes. Defendant subsequently filed a motion to vacate his convictions, which the postconviction court denied. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus, contending that his appellate counsel provided ineffective assistance. The Supreme Court affirmed the postconviction court's denial of Defendant's motion for postconviction and denied habeas corpus relief, holding (1) the postconviction court did not err in denying (i) thirteen of Defendant's claims of ineffective assistance of counsel, as Defendant did not demonstrate that he was prejudiced by any error made by trial counsel, and (ii) Defendant's claim that his death sentences were unconstitutional under Ring v. Arizona, as Defendant's claim based on Ring was procedurally barred and without merit; and (2) Defendant's habeas claim was without merit. View "Victorino v. State" on Justia Law