Justia Constitutional Law Opinion Summaries

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

Plaintiffs filed a class action complaint against a check advance company, asserting claims based on numerous Florida statutes. Plaintiffs later amended the complaint to add Tiffany Kelly as an additional plaintiff and named class member. Because Kelly had signed the version of Defendant's arbitration agreement that contained a class action waiver, this case focused on her contracts with Defendant. The trial court eventually denied Defendant's motion to compel arbitration, ruling that the class action waiver was unenforceable because it was void as against public policy. The court of appeal affirmed, finding that no other reasonable avenue for relief would be available if it enforced the class action waiver. After the court of appeal decided this case, the U.S. Supreme Court issued its decision in AT&T Mobility, LLC v. Concepcion. Applying the rationale of Concepcion to the facts set forth in this case, the Supreme Court quashed the court of appeal's decision, holding that the Federal Arbitration Act preempted invalidating the class action waiver in this case on the basis of the waiver being void as against public policy. View "McKenzie Check Advance of Fla., LLC v. Betts" on Justia Law

Plaintiff, the personal representative of the estate of Charlotte Douglas, filed a complaint against cigarette companies and industry organizations for damages on claims based on Charlotte's smoking-related death. After a jury trial, Plaintiff was awarded $2.5 million in damages. At issue on appeal was whether the trial court erred in the application of the Phase I findings in the class action case Engle v. Liggett Group, Inc. Charlotte was a member of the Engle class. The court of appeal affirmed, concluding that Plaintiff did not prove legal causation on his negligence theory but did prove legal causation on his strict liability claim. Although the court of appeal rejected Defendants' argument that applying res judicata to the findings violated their due process rights, it certified the due process question to the Supreme Court. The Court approved of the court of appeal's decision affirming the general verdict for Plaintiff based on strict liability but disapproved the court's rejection of negligence as a basis for the general verdict because the court's analysis required causation instructions and findings beyond those required by Engle. In addition, the Court answered that accepting as res judicata the eight Phase I findings approved in Engle did not violate Defendants' due process rights. View "Philip Morris USA Inc. v. Douglas" on Justia Law

Defendant was convicted of first-degree murder and sentenced to death. After his initial postconviction motion was denied, Petitioner filed an amended successive postconviction motion to vacate his judgments and sentence. Defendant filed a motion for discovery with regard his postconviction claim of newly discovered evidence, seeking production of a photograph card of an unidentified fingerprint found on the victim's check, which Defendant sought to compare with that of a deceased death row inmate. The postconviction court denied Defendant's motion for discovery and summarily denied his amended successive postconviction motion. The Supreme Court affirmed, holding (1) the postconviction court correctly summarily denied relief on the postconviction motion, as (i) Defendant's claim was time-barred, and furthermore, the record showed Defendant was not entitled to relief; (ii) Defendant was not entitled to a new trial based on newly discovered evidence; and (iii) Defendant was not deprived of his due process rights to present evidence on his challenge to Florida's lethal injection procedures. The Court also affirmed the circuit court's denial of Defendant's motion for discovery, as Defendant did not show his request would result in discovery of relevant or material evidence. View "Reed v. State" on Justia Law

In 1976, Defendant was convicted of the first-degree murders of his wife Eunice Zeigler and Charlie Mays and the second-degree murders of his in-laws, Perry and Virginia Edwards. In 2001, the trial court granted Defendant's motion for DNA testing for the purposes of clemency proceedings. After the testing was completed, Defendant filed a motion to vacate his sentences, arguing that the presence of Perry's blood on Mays' clothing corroborated his testimony that Mays was a perpetrator rather than a victim. The trial court denied the motion, and the Supreme Court affirmed. In 2009, Defendant filed a motion for postconviction DNA testing requesting further testing of the victims' clothing. Following an evidentiary hearing, the circuit court denied Defendant's motion. The Supreme Court affirmed, holding that Defendant had not met his burden of showing how the results of the DNA testing would give rise to a reasonable probability of a different outcome. View "Zeigler v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and was sentenced to death. The Supreme Court affirmed Defendant's conviction and sentence, holding (1) Defendant's claims regarding the constitutionality of certain aggravators and jury instructions were denied because Defendant provided no reasons that the Court should depart from its precedent upholding the constitutionality of these aggravators and instructions; (2) competent, substantial evidence supported Defendant's murder conviction; and (3) under the totality of the circumstances, Defendant's death sentence was proportional in relation to other death sentences the Court has upheld. View "Matthews v. State" on Justia Law