Justia Constitutional Law Opinion Summaries

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

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