Justia Constitutional Law Opinion Summaries

Petitioner was a juvenile charged as an adult with attempted first-degree murder with a deadly weapon. After the U.S. Supreme Court issued its decision in Graham v. Florida, Petitioner filed a motion to have a bond set. The trial court denied the motion. Petitioner filed a second petition for writ of habeas corpus, arguing (1) the Florida Constitution provides for pretrial release as a matter of right for a noncapital offense or an offense that does not carry the possibility of a life sentence, and (2) because Graham prohibits the State from sentencing him to life without an opportunity for parole, he was entitled to bond under the provisions of the State Constitution. The court of appeal denied the petition, concluding that Graham does not impact a juvenile defendant's entitlement to bond because the Florida Constitution considers only the classification of the offense, not a defendant's eventual sentence. The Supreme Court quashed the decision below, holding that juvenile offenders such as Petitioner were entitled to bond under the Florida Constitution because they cannot be charged with a crime punishable by life imprisonment under Florida's current statutory scheme and Graham. View "Treacy v. Lamberti" on Justia Law

This was the second time this case was before the Supreme Court. In the Court's previous decision, the Court quashed the court of appeal's decision, holding that the trial court should have granted Defendant's motion to suppress evidence obtained from a search of Defendant's truck, holding that law enforcement officers lacked probable cause where "the fact that a drug-detection dog has been trained and certified to detect narcotics, standing alone, is not sufficient to demonstrate the reliability of the dog." The U.S. Supreme Court reversed, holding that because the training records established the dog's reliability in detecting drugs in this case, and because Defendant failed to undermine that showing, the police officer had probable cause to search Defendant's truck. On remand, the Florida Supreme Court withdrew its prior opinion and approved of the court of appeal's decision in Harris I. View "Harris v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder and burglary. Defendant appealed, alleging that the trial court's failure to remove a prospective juror for cause resulted in a denial of his right to a fair and impartial jury as guaranteed by the state and federal constitutions. The court of appeal affirmed, concluding that the juror was competent to serve. The Supreme Court quashed the decision of the third district and remanded for a new trial, holding that the juror demonstrated during voir dire that she could not fulfill her role as a fair and impartial arbiter and thus should have been excused for cause. View "Matarranz v. State" on Justia Law

After a jury trial, Defendant was convicted of burglary of a dwelling with an assault or battery with a dangerous weapon, robbery with a weapon, and carjacking with a dangerous weapon. The court of appeal affirmed Defendant's convictions for burglary of a dwelling and carjacking but certified conflict on the issues of (1) whether Florida's burglary statute requires a structure to be suitable for habitation on the date of the offense for the structure to meet the definition of a dwelling, and (2) whether a defendant can be convicted of carjacking where the force used in the robbery on the inside of the building is separate from the taking of the vehicle on the outside of the building. The Supreme Court affirmed the court of appeal, holding (1) a structure undergoing substantial renovations constitutes a "dwelling" under the relevant statute; and (2) Defendant's actions constituted a carjacking under the relevant statute. View "Young v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder, two counts of robbery, and two counts of kidnapping. The trial court sentenced Defendant to concurrent sentences of death for both murders. The Supreme Court affirmed the convictions and sentences of death. Defendant subsequently filed a motion for postconviction relief, alleging that his trial counsel provided ineffective assistance. The postconviction court denied all of Defendant's claims. The Supreme Court affirmed the denial of relief and denied Defendant's petition for a writ of habeas corpus, holding (1) trial counsel did not provide constitutionally defective assistance; (2) Florida's death sentencing scheme is constitutional; and (3) Defendant's appellate counsel did not provide ineffective assistance. View "Jackson v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed the first-degree murder conviction and death sentence, holding (1) the trial court did not err in finding a cold, calculated and premeditated aggravator; (2) Defendant's death sentence was proportionate; (3) the penalty-phase jury instructions did not violate Caldwell v. Mississippi, and Ring v. Arizona did not require the reversal of Defendant's death sentence; (5) the trial court did not err in refusing to permit Defendant to present guilt-phase evidence of his mental condition at the time of the murder; and (6) competent, substantial evidence supported the verdict beyond a reasonable doubt. View "Brown v. State" on Justia Law

Defendant was charged with burglary, grand theft, dealing in stolen property, and providing false information to a pawnbroker. The trial court refused to refer to Fla. Stat. 812.025 in its jury instructions or otherwise instruct the jury that it was precluded from finding Defendant guilty of both dealing in stolen property and theft. Defendant was convicted of all of the charges, but the trial judge subsequently dismissed the grand theft conviction. Defendant appealed, arguing that he was entitled to a new trial because the trial court denied his requested instruction modeled on section 812.025. The court of appeal affirmed. The Supreme Court quashed the decision of the court of appeal, holding (1) a trial court must instruct the jury pursuant to section 812.025 when both theft and dealing in stolen property offenses are submitted to the jury; (2) if a trial court denies a defendant's request for a jury instruction under section 812.025, the defendant must be given a new trial if the jury convicts the defendant of both theft and dealing in stolen property; and (3) Defendant was entitled to a new trial on the dealing in stolen property and grand theft counts. View "Williams v. State" on Justia Law

Defendant was charged with burglary, petit theft, and dealing in stolen property. The trial court did not instruct the jury it could not return a guilty verdict for both theft and dealing in stolen property pursuant to Fla. Stat. 812.025, and Defendant did not request such an instruction. The jury found Defendant guilty of both offenses. Defendant appealed, asserting that he was entitled to a new trial because he was convicted of both petit theft and dealing in stolen property in violation of section 812.025. The district court concluded that although Defendant did not object to the dual convictions at trial, he was permitted to challenge the convictions on appeal. The court then vacated the petit theft conviction. The Supreme Court affirmed, holding (1) although the trial court erred in rendering the dual convictions, it was not fundamental error such that would require a new trial; and (2) accordingly, the district court properly affirmed Defendant's dealing in stolen property conviction while reversing his petit theft conviction. View "Blackmon v. State" on Justia Law

On May 13, 2013, the Governor signed a death warrant for Defendant and set the execution date. After Defendant's state counsel wrote the Governor a letter stating there was reason to believe Defendant was insane to be executed, a group of psychiatrists conducted an examination of Defendant and concluded that Defendant was sane to be executed. Defendant's federal counsel subsequently filed a motion for stay and hearing, challenging Defendant's competency to be executed. After an evidentiary hearing, the circuit court found Defendant sane to be executed and lifted its stay. The Supreme Court affirmed, holding that competent, substantial evidence supported the circuit court's determination that Defendant was sane to be executed. View "Gore v. State" on Justia Law

In 2003, Petitioner was convicted of committing various offenses and was sentenced to terms of imprisonment. Petitioner subsequently filed numerous nonmeritorious pleadings and requests for relief related to his criminal convictions. Petitioner's petitions in the instant cases were denied as procedurally barred in 2012, and Petitioner was ordered to show cause why he should not be barred from filing in the Court any future pro se pleadings or requests for relief pertaining to his criminal convictions. After Petitioner failed to file a response, the Supreme Court barred Petitioner from any future pro se filings related to his criminal convictions and concluded that Petitioner's petitions in these cases were frivolous proceedings initiated by a prisoner. View "Werdell v. Crews" on Justia Law