Justia Constitutional Law Opinion Summaries

Among other crimes, Defendant pleaded guilty to the first-degree murder of Michelle Simms and was sentenced to death. The Supreme Court vacated the death sentence and remanded. After the second sentencing proceeding, the trial judge imposed the death sentence for the first-degree murder. Defendant subsequently filed a postconviction motion, raising claims of ineffective assistance of counsel. The circuit court denied relief on all claims. The Supreme Court affirmed the trial court's denial of Defendant's postconviction motion, holding that the circuit court (1) did not err in denying Defendant's claim of ineffective assistance of defense counsel regarding Defendant's guilty plea; and (2) did not err in summarily denying Defendant's claim of ineffective assistance of counsel for failure to object to prosecutorial misconduct during the penalty phase. View "Long v. State" on Justia Law

Defendant pled nolo contendere to a misdemeanor driving with a suspended license charge in violation of Fla. Stat. 322.34(2) and was sentenced to a term of probation. On the same day, the state attorney filed an information charging Defendant with a violation of the felony unlawful driving as a habitual traffic offender statute, Fla. Stat. 322.34(5). Defendant filed a motion to dismiss the information, arguing that it violated Florida's prohibition against double jeopardy. The circuit court granted Defendant's motion to dismiss the felony information. The court of appeal reversed. The Supreme Court quashed the decision of the court of appeal and concluded that the trial court properly granted the motion to dismiss the felony information, holding that dual prosecutions under (2) and (5) of section 322.34 are both statutorily and constitutionally prohibited. View "Gil v. State" on Justia Law

In 2010, voters approved an amendment to the Florida Constitution providing for express new state constitutional standards to govern the apportionment of legislative districts. Those standards were enumerated in Fla. Const. art. III, 21. Pursuant to its Fla. Const. art. III, 16 jurisdiction, the Supreme Court declared the Legislature's original plan apportioning districts for the Senate to be facially invalid, whereupon the Legislature adopted a revised plan. The Supreme Court upheld the facial validity of the revised plan. Plaintiffs subsequently filed a complaint alleging that the revised Senate map violated the express standards contained in article III, section 21. The Legislature moved to dismiss the complaint with prejudice, asserting that the circuit court lacked jurisdiction to adjudicate a challenge to the 2012 legislative apportionment plan. After the circuit court denied the motion, the Legislature sought extraordinary relief directing the circuit court to dismiss the complaint. The Supreme Court held that the circuit court had subject matter jurisdiction to adjudicate fact-based challenges to the validity of the 2012 legislative apportionment plan, that the circuit court's exercise of jurisdiction here would not interfere with the binding judgment of the Supreme Court, and that the Legislature failed to meet its burden of demonstrating entitlement to relief. View "Fla. House of Representatives v. League of Women Voters of Fla. " on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and kidnapping. The trial court imposed a sentence of death. Defendant appealed. The Supreme Court affirmed the convictions and sentences, holding (1) the trial court did not err in limiting the defense's cross-examination of a State witness; (2) there was sufficient evidence to support Defendant's convictions; (3) the prosecutor asked improper questions of Defendant's mental health expert, but the error was harmless; (4) the trial court did not err in finding certain aggravating circumstances; (5) the trial court did not err in rejecting certain statutory mental mitigators and in assigning weight to the nonstatutory mitigation; and (6) the death sentence in this case was proportional. View "Allen 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 a motion for postconviction relief, which the postconviction court denied. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court (1) affirmed the postconviction court's denial of relief as to Defendant's guilt phase claims; (2) reversed the court's denial of relief as to Defendant's claim of ineffective assistance of trial counsel at the penalty phase, as Defendant established that he was prejudiced by his counsel's deficient performance during the penalty phase; and (3) denied Defendant's petition for writ of habeas corpus. Accordingly, the Court vacated the sentence of death and remanded for a new penalty phase proceeding. View "Shellito v. State" on Justia Law

Defendant pled guilty to first-degree murder and armed robbery and waived a penalty-phase jury. After penalty-phase proceedings in front of the trial judge, the trial court sentenced Defendant to death. The Supreme Court affirmed Defendant's convictions and sentence of death, holding (1) Defendant's guilty plea was knowingly, intelligently, and voluntarily entered; (2) any possible error in the trial court not considering polygraph results as mitigating evidence was harmless beyond a reasonable doubt; (3) the trial court did not err in not giving significant weight to the mitigator of Defendant's age, which was nineteen years old at the time of the crime; and (4) the death sentence in this case was proportional. View "Sanchez-Torres v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant's conviction and sentence of death, holding (1) the trial court did not err in instructing the jury on and in finding that the murder was especially heinous, atrocious, or cruel; (2) Defendant's death sentence was proportionate and constitutional; (3) the prosecutor did not commit misconduct in his statements during closing arguments; (4) the trial court did not err in precluding the defense from arguing a lack of violent criminal history during its penalty-phase closing argument; (5) the evidence was sufficient to support Defendant's conviction for first-degree murder. View "King v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree premeditated murder and sentenced to death for each murder. The Supreme Court affirmed the convictions and sentences on direct appeal. The postconviction court later denied Defendant's unverified postconviction motion. Defendant appealed and filed a petition seeking habeas corpus relief. The Supreme Court affirmed the trial court's order and denied the petition for a writ of habeas corpus, holding (1) Defendant waived right to prosecute his postconviction motion by refusing to sign a verification of his motion; (2) the trial court did not err in finding Defendant competent to proceed with his postconviction proceedings with the assistance of counsel; and (3) Defendant's petition for habeas corpus relief was not warranted on his claim that his case should be remanded for a determination of whether he should have been permitted to represent himself at trial. View "Hernandez-Alberto v. State" on Justia Law

After a jury trial in which the jury rejected Defendant's insanity defense, Defendant was convicted of three counts of first-degree murder and sentenced to two terms of life imprisonment and one sentence of death. The Supreme Court (1) affirmed the convictions for first-degree murder; (2) affirmed the sentences of life imprisonment; but (3) vacated the death sentence, finding that the sentence of death was disproportionate in this case, which involved substantial mental health mitigation due to evidence Defendant was suffering from some type of psychosis at the time of the offenses and Defendant's extensive history of abuse and neglect. Remanded for imposition of an additional sentence of life in prison. View "Davis v. State" on Justia Law

After a jury trial, Defendant was convicted and sentenced to death for the murder of a law enforcement officer and convicted of attempted first-degree murder and aggravated battery of two other law enforcement officers. The Supreme Court affirmed. Defendant subsequently filed amended and supplemental motions for postconviction relief, which the postconviction court denied after an evidentiary hearing. Defendant appealed that the denial and filed a petition for a writ of habeas corpus. The Supreme Court affirmed the denial of postconviction relief and denied the petition for a writ of habeas corpus, holding (1) Defendant failed to establish that he was prejudiced by his counsel's representation, and thus he was not entitled to relief on his claims of ineffective assistance of counsel; (2) Defendant failed to establish that his appellate counsel was ineffective; (3) Florida's capital clemency process is constitutional; and (4) Florida's capital sentencing scheme is constitutional. View "Wheeler v. State" on Justia Law