Justia Constitutional Law Opinion Summaries

Defendant was convicted of first-degree murder and sexual battery and sentenced to death. The Supreme Court affirmed Defendant's convictions and death sentence on direct appeal. Defendant subsequently filed a several post-conviction motions, which were ultimately unsuccessful. After the governor set a date for Defendant's execution, Defendant filed a successive postconviction motion, raising four claims. The circuit court summarily denied relief on all claims. The Supreme Court affirmed, holding (1) Defendant's claim that his mental illness should exempt him from execution was untimely and procedurally barred; (2) Defendant's claim that the death warrant selection process was arbitrary, thus rendering the death penalty unconstitutional, was without merit; (3) Defendant's claim that the clemency process he received was conducted in an arbitrary and capricious manner was without merit; and (4) Defendant's claim that adding execution to the "inordinate length of time" he spent on death row would constitute cruel and unusual punishment was without merit. View "Carroll v. State" on Justia Law

After a jury trial, Defendant was convicted of the 2001 first-degree murder of his wife. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant's conviction and sentence. Defendant subsequently filed a motion for postconviction relief, raising several claims. The circuit court denied relief. The Supreme Court affirmed, holding that the postconviction court correctly denied relief on Defendant's claims of ineffective assistance of trial counsel, as (1) counsel's failure to investigate and present evidence that Defendant had organic brain damage did not undermine confidence in the sentence; (2) counsel was not constitutionally deficient regarding the child witnesses who testified at Defendant's trial; and (3) counsel's failure to present evidence regarding the registration of the gun used in the homicide did not undermine confidence in Defendant's sentence; and (4) counsel made a reasonable strategic decision to have Defendant wear jail clothing during the penalty phase. View "Rodgers v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, armed burglary, extortion, three counts of attempted murder, five counts of armed kidnapping, and four counts of armed robbery. Defendant was respectively sentenced to death and multiple terms of imprisonment. The Supreme Court later vacated Defendant's convictions and sentences on the attempted murder charges. Defendant subsequently filed a motion to vacate his first-degree murder conviction and sentence of death, raising several claims of ineffective assistance of counsel. The postconviction court denied relief on Defendant's claims. The Supreme Court affirmed, holding that, even assuming trial counsel's alleged deficiencies, they did not so affect the fairness and reliability of the proceeding that confidence in the outcome was undermined. View "Williamson v. State" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant's conviction and death sentence on direct appeal. Defendant subsequently filed a motion for postconviction relief. The trial court denied the motion after an evidentiary hearing. The Supreme Court remanded for a new evidentiary hearing, after which the circuit court issued an order denying postconviction relief on all claims. Defendant appealed and petitioned the Supreme Court for a writ of habeas corpus. The Court affirmed the denial of Defendant's motion for postconviction relief and denied his habeas petition, holding (1) the State did not commit Brady v. Maryland violations during trial or violate Giglio v. United States by failing to correct false or misleading testimony; (2) Defendant was given effective assistance of counsel at trial; (3) Defendant's claims that he was tried while incompetent were procedurally barred and without merit; and (4) because Defendant failed to demonstrate either deficient performance or prejudice on the part of his trial counsel, his habeas petition failed. View "Wickham v. State" on Justia Law

After a jury trial, Defendant was convicted of robbery and possession of a firearm by a convicted felon. The trial court sentenced Defendant to fifty years' incarceration on the robbery conviction and fifteen years' incarceration on the possession conviction. Defendant appealed the denial of his motion to suppress the search of information stored within his cell phone incident to his arrest. The court of appeal affirmed the trial court's decision in the admissibility of images found on Defendant's cell phone but certified a question to the Supreme Court as a matter of great public importance. The Supreme Court quashed the decision of the court of appeal and remanded, holding (1) the holding in United States v. Robinson does not allow a police officer to search through photographs contained within a cell phone that is on an arrestee's person at the time of a valid arrest; and (2) while law enforcement officers properly separated and assumed possession of a cell phone from Defendant's person during the search incident to arrest, a warrant was required before the information, data, and content of the cell phone could be accessed and searched by law enforcement. View "Smallwood v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended the death penalty by a vote of seven to five, and the trial court sentenced Defendant to death. The Supreme Court affirmed. Defendant subsequently filed a second amended initial motion for postconviction relief and supplemental addendum, presenting several claims. The postconviction court denied the motion and addendum. The Supreme Court affirmed the denial of Defendant's motion, holding (1) Defendant was afforded effective assistance of counsel at trial; (2) Defendant was not entitled to a claim of cumulative error because he failed to prevail on any individual claim of ineffectiveness; and (3) Defendant was not entitled to relief on his claims that Florida's death penalty violates Ring v. Arizona and is unconstitutional. View "McCoy v. State" on Justia Law

After a jury trial, Defendant was convicted of the first-degree murders of two Clearwater residents and received two sentences of death. The Supreme Court affirmed the trial court's judgments of conviction and sentences of death, holding (1) Defendant's argument that his penalty phase counsel penalty provided ineffective assistance did not warrant relief on direct appeal, as ineffective assistance of counsel claims are not cognizable on direct appeal; (2) Defendant's death sentences were not unconstitutional because they were based on a seven-to-five bare majority recommendation by the jury; (3) the trial court did not commit error in suggesting to the State that it seek the prior capital felony aggravating circumstance; (4) the State's closing argument during the guilt phase did not warrant a new trial; (5) substantial evidence supported each of Defendant's convictions; and (6) Defendant's death sentences were proportional to similar cases where the Court affirmed the sentence of death. View "Robards v. State" on Justia Law

In 1972, Petitioner was convicted and sentenced to life imprisonment for committing capital sexual battery. In a separate case, Petitioner pled guilty to of unlawful use of a motor vehicle. From 1992 forward, Petitioner filed multiple pro se extraordinary writ petitions and other proceedings with the Supreme Court seeking relief from his conviction and sentence. None of the petitions for relief was granted. In the instant case, Petitioner filed pro se petitions for writs of habeas corpus. The Court dismissed the petitions as unauthorized pursuant to Baker v. State and found them to be frivolous proceedings. Because the petitions were dismissed as unauthorized and also were the ninth and tenth pro se proceedings initiated by Petitioner in the Court, and because Petitioner failed to show cause why he should not be sanctioned, the Court instructed the clerk of court to reject any future pleadings, petitions or filings submitted by Petitioner related to his criminal cases. View "McCutcheon v. State" on Justia Law

Defendant was convicted of first-degree murder and robbery with a deadly weapon. Defendant appealed, arguing that the trial judge erred in refusing to allow Defendant to call a witness despite defense counsel's determination that calling the witness would not be of benefit to Defendant's case. The Fourth District court of appeal held that determining which witnesses should be called by the defense is not a fundamental decision to be made by the defendant himself, and therefore, the trial court did not err in its judgment. The Fourth District subsequently certified conflict with the Fifth District's decision in Cain v. State. The Supreme Court (1) approved the decision of the Fourth District in this case and disapproved the decision of the Fifth District in Cain, holding that defense counsel has the final authority as to whether or not the defense will call a particular witness to testify at the criminal trial; and (2) receded from its decision in Blanco v. State to the extent it held that the ultimate decision rests with the defendant as to the presentation of witnesses. View "Puglisi v. State" on Justia Law

Petitioner was convicted under Fla. Stat. 790.19 for shooting into an unoccupied vehicle. The trial court determined Petitioner qualified as a prison releasee reoffender (PRR) under the forcible felony catch-all provision of the PRR statute and thus sentenced him to a prison term of fifteen years for the conviction. Petitioner filed a motion for postconviction relief disputing the validity of his sentence, claiming that his conviction was not a qualifying felony under the forcible felony catch-all provision of the PRR statute. The trial court denied the motion, and the fourth district court of appeal affirmed. The court, however, certified conflict with the first district's decision in Crapps v. State. The Supreme Court (1) approved the fourth district's decision, finding that the offense of shooting into an occupied vehicle necessarily involves the use or threat of physical force or violence against an individual, and therefore, qualifies as a forcible felony under the catch-all provision of the PRR statute; and (2) disapproved the opinion in the conflicting case of Crapps. View "Paul v. State" on Justia Law