Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of armed kidnapping, armed sexual battery, and armed robbery. The trial court sentenced Defendant to concurrent, upward departure sentences of forty-eight years on each count. Defendant's sentences became final in 2000, after the U.S. Supreme Court's issued its decision in Apprendi v. New Jersey. In 2002, the trial court granted Defendant's postconviction motion to correct illegal sentence and resentenced Defendant to concurrent terms of forty years on two counts and reinstated the forty-eight-year sentenced for the armed robbery. In 2004, the U.S. Supreme Court issued its decision in Blakely v. Washington. In 2007, Defendant filed a motion alleging that the upward departure sentences imposed at his 2002 resentencing exceeded the statutory maximum as defined by Blakely. The trial court denied the motion. The court of appeal reversed, holding that Blakely's new definition of "statutory maximum" applied retroactively to cases on collateral review in which sentences were imposed after the U.S. Supreme Court's decision in Apprendi. The Supreme Court reversed, holding that Blakely does not apply retroactively to final sentences or resentences. View "State v. Johnson" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sexual battery. The trial court sentenced Defendant to death on the murder conviction. The Supreme Court affirmed the convictions and sentence of death on direct appeal. Defendant subsequently filed an amended motion to vacate judgment of conviction and sentence. After an evidentiary hearing, the circuit court vacated Defendant's judgment of guilt of first-degree murder and his sentence of death and ordered a new trial, concluding that Defendant established the deficiency and prejudice prongs of Strickland v. Washington for his claims of ineffective assistance of counsel and had established cumulative error. The Supreme Court affirmed, holding (1) Defendant's trial counsel provided constitutionally deficient representation during the guilt phase; and (2) Defendant was entitled to a new trial. View "State v. Fitzpatrick" on Justia Law

Plaintiff filed suit against County, alleging he was negligently shot by a police officer responding to a burglary alarm at his place of business. County argued it was entitled to immunity because the officer's actions were discretionary and fell under the police emergency exception. The trial court denied County's summary judgment motion as to the negligence claim and granted its motion as to the negligent retention claim. County filed a petition for writ of certiorari with the court of appeal. The court of appeal granted the writ, concluding that the undisputed facts showed a police emergency exception conferred sovereign immunity on County. The Supreme Court quashed the court of appeal's decision, holding (1) County's claim that it was entitled to sovereign immunity was not reviewable by the appellate courts through a petition for writ of certiorari; and (2) the court of appeal erred in concluding that County was entitled to summary judgment based on the police emergency exception. Remanded. View "Rodriguez v. Miami-Dade County" on Justia Law

Defendant was convicted and sentenced to life imprisonment for committing capital sexual battery. In a separate case, Defendant pled guilty to unlawful use of a motor vehicle. Defendant subsequently filed multiple pro se extraordinary writ petitions and other proceedings seeking relief from his conviction and sentence. In none of the petitions filed in the Supreme Court was any relief granted. The petitions in the instant consolidated cases were the ninth and tenth pro se proceedings initiated by Defendant in the Court. The petitions were dismissed as unauthorized. The Court subsequently sanctioned Defendant and concluded that Defendant's unauthorized petitions were frivolous proceedings, thus directing the Clerk of Court to reject any future filings submitted by Defendant related to his criminal cases unless signed by an attorney. View "McCutcheon v. State" on Justia Law

Defendant was convicted of two counts of first-degree murder and sentenced to death. The Supreme Court affirmed. Defendant subsequently filed an extensive history of successive postconvictions motions and extraordinary writ petitions, which were all either denied or dismissed. In the current proceedings, Defendant had three cases pending before the Supreme Court, including appeals from the denials of two successive motions for postconviction relief and a petition for a writ of prohibition challenging the postconviction court's denial of his motion to disqualify the judge. The Supreme Court affirmed the denial of Defendant's successive motions for postconviction relief and denied the petition for a writ of prohibition challenging the postconviction court's denial of Defendant's motion to disqualify, holding that all of these proceedings were "utterly without merit." View "Lambrix v. State" on Justia Law

After a jury trial, Defendant was convicted of three counts of first-degree murder and sentenced to death for each murder. The Supreme Court affirmed. Defendant subsequently filed an amended motion for postconviction relief, raising twenty-five claims. The postconviction court granted an evidentiary hearing on five of Defendant's claims, after which the court denied relief. Defendant appealed and simultaneously petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of Defendant's postconviction claims and denied habeas relief, holding (1) Defendant failed to establish he was prejudiced by his counsel's representation, and therefore, he was not entitled to relief on his claims of ineffective assistance of counsel; (2) the postconviction court did not err in summarily denying three of Defendant's claims; and (3) appellate counsel did not provide ineffective assistance. View "Jennings v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder, one count of burglary, and one count of possession of a firearm by a convicted felon. The trial court sentenced Defendant to death for both murders. The Supreme Court affirmed the convictions and sentences, holding (1) the trial court did not err in denying Defendant's motion to disqualify the judge; (2) the trial court did not prejudicially err in its evidentiary rulings during the guilt phase of trial; (3) the trial court did not err in finding the murders were committed in a cold, calculated, and premeditated manner, without any pretense of moral or legal justification; (4) sufficient evidence supported Defendant's convictions; and (5) Defendant's death sentences were proportionate. View "Gregory v. State" on Justia Law

After waiving counsel, Defendant pled guilty to and was convicted of first-degree murder. Following the penalty phase, Defendant was sentenced to death and to terms of imprisonment for the related charges of burglary, sexual battery, and arson. The Supreme Court affirmed on direct appeal. Defendant subsequently filed a motion for postconviction relief. The circuit court summarily denied the motion. The Supreme Court affirmed, holding (1) the trial court and Defendant's standby counsel did not err in failing to order a competency evaluation before allowing him to plead guilty, as the record supported the conclusion that Defendant was competent; and (2) Defendant's claim that his death sentence violated the Eighth Amendment because he may be incompetent at the time of execution was not ripe for review. View "Barnes v. State" on Justia Law

Defendant was convicted in 1982 to capital sexual battery and sentenced to life imprisonment. The court of appeal affirmed Defendant's conviction and sentence. Since then, Defendant made many pro se filings in the Supreme Court that were devoid of merit or inappropriate for review in the Court. At issue in this case was a recent pro se habeas petition filed by Defendant seeking to challenge his conviction and sentence. The Supreme Court dismissed the petition as unauthorized under Baker v. State. The Court also retained jurisdiction and ordered Defendant to show cause why he should not be barred from further pro se filings related to that criminal case and why the Court should not determine his filing was frivolous. After Defendant responded, the Court concluded that Defendant failed to show cause why he should not be sanctioned. Accordingly, the Court found the current finding frivolous and ordered the clerk of court to reject any future pro se pleadings or filings submitted by Defendant. View "Myles v. Crews" on Justia Law

After a trial, Defendant was convicted of first-degree murder and sentenced to death. After the denial of his first request for postconviction relief, Defendant filed a successive motion for postconviction relief, asserting that newly discovered evidence from a new witness impeached the only witness who identified Defendant as leaving the crime scene immediately after the murder, and demonstrated that the State violated Brady v. Maryland and Giglio v. United States. The postconviction court summarily denied relief. The Supreme Court remanded the Brady and Giglio claims for an evidentiary hearing but affirmed the order denying the newly discovered evidence claim. The postconviction court held an evidentiary hearing on remand and again denied relief. The Supreme Court affirmed, holding (1) substantial evidence supported the postconviction court's finding that Defendant failed to show the State willfully suppressed favorable evidence in violation of Brady; and (2) the postconviction court correctly denied Defendant's claim that the State knowingly presented false testimony in violation of Giglio. View "Mungin v. State" on Justia Law