Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. Defendant appealed, contending, among other things, that the trial court erred when it denied his motion to suppress his confession because, during his interrogation and before he confessed to the murder, he invoked his right to remain silent. The Supreme Court reversed and remanded for a new trial, holding (1) based on the totality of the circumstances, the police did not scrupulously honor Defendant's invocation of his right to remain silent; (2) there was not competent, substantial evidence to support the trial court's finding that Defendant's confession was voluntary; and (3) the State failed to establish that this error was harmless beyond a reasonable doubt. View "Deviney v. State" on Justia Law

Defendant was convicted of first-degree murder. After a retrial, Defendant was again convicted of first-degree murder and sentenced to death. The Supreme Court affirmed Defendant's conviction and sentence, holding (1) the admission of testimony from Defendant's first trial did not violate Defendant's right to confrontation or to due process; (2) the trial court did not err in admitting a suicide note Defendant wrote while incarcerated; (3) the evidence was sufficient to support a first-degree murder conviction; (4) the trial court did not err in rejecting a proposed statutory mental mitigator; and (5) Defendant's death sentence was proportional in this case. View "Bolin v. State" on Justia Law

Defendant constructed a bomb with the specific purpose of killing a witness, but the bomb instead detonated and killed a highway patrol trooper. After a jury trial, Defendant was convicted of first-degree murder and of making, possessing, placing, or discharging a destructive device or bomb. Defendant was sentenced to death. After the execution was set for February 26, 2013, Defendant filed a successive motion for postconviction relief, which the trial court summarily denied. The Supreme Court affirmed the denial of Defendant's motion for postconviction relief and denied Defendant's motion for a stay of execution, holding (1) the trial court did not err in denying Defendant's motion to remove appointed registry counsel; (2) the trial court did not err in denying Defendant's motions to appoint experts and investigators; (3) the trial court did not err in finding that lethal injection did not constitute cruel and unusual punishment; and (4) Defendant failed to show that there were substantial grounds upon which relief might be granted regarding his application for a stay of execution. View "Howell v. State" on Justia Law

Defendant was convicted and sentenced for lewd and lascivious molestation on a victim under twelve years of age by an offender eighteen years of age or older and for failure to appear. Defendant appealed, arguing that certain comments made by a prosecutor during closing argument were improper. The court of appeal affirmed, holding, among other things, that because the victim's age was not an issue which only Defendant was capable of refuting, the prosecutor's comment in regard to the victim's age could not be construed as a comment on Defendant's right to remain silent. The Supreme Court affirmed, holding (1) the prosecutor's comment did not constitute an improper comment on Defendant's right to remain silent; (2) the court of appeal erred in holding that a second comment likewise did not constitute an improper comment on Defendant's right to remain silent and that two additional comments constituted improper burden shifting; but (3) the objections to the improper comments were not preserved for appellate review, and because the comments did not constitute fundamental error, they did not require reversal. View "Bell v. State" on Justia Law

Appellant was sentenced to death for the 2000 murders of an elderly couple. The Supreme Court affirmed Appellant's convictions but reversed the death sentences and remanded for a new penalty phase. After a new penalty phase, the trial court followed the jury's recommendation and imposed two death sentences for the murders. The Supreme Court affirmed the sentences, holding that the trial court did not err in (1) finding that Appellant was not mentally retarded; (2) admitting a video of a statement Appellant made to law enforcement; (3) instructing the jury on its advisory role and denying Appellant's proposed instruction regarding victim impact evidence; (4) allowing the prosecution to cross-examine mental health experts regarding their knowledge of the facts surrounding the murders; and (5) considering and weighing several aggravators and mitigators. Lastly, the Court found that the prosecutor made permissible comments at closing argument and that the death sentence was proportionate in this case. View "Snelgrove v. State" on Justia Law

In 2007, the Legislature passed several statutes and included a provision in the 2007-2008 General Appropriations Act that exerted control over the setting of and appropriating for the expenditure of tuition and fees for the Florida university system. Petitioners challenged these statutes as unconstitutional, contending that the 2002 constitutional amendment creating the Board of Governors transferred the authority over tuition and fees to the Board, thus divesting the Legislature of any power over these funds. The trial court granted summary judgment in favor of the Legislature, and the court of appeal affirmed. The Supreme Court affirmed, holding that the challenged statutes by which the Legislature exercised control over the funds was facially constitutional, as (1) the constitutional source of the Legislature's control over the setting of and appropriating for the expenditure of tuition and fees derives from its power under Fla. Const. art. VII, 1(c) and (d) to raise revenue and appropriate for the expenditure of state funds; and (2) the language of the 2002 amendment is devoid of any indication of an intent to transfer this power to the Board. View "Graham v. Haridopolos" on Justia Law

Defendant was convicted of first-degree murder and was sentenced to death. The Supreme Court affirmed Defendant's sentence. Defendant filed a postconviction motion alleging ineffective assistance of counsel. The postconviction court denied the motion after an evidentiary hearing. Defendant appealed and also filed a habeas corpus petition. The Supreme Court affirmed the trial court's denial of Defendant's postconviction motion and denied his habeas petition, holding (1) Defendant did not establish that he received ineffective assistance of counsel, and therefore, his postconviction motion was correctly denied; (2) cumulative error did not deprive Defendant of a fair trial; (2) Defendant's sentence did not constitute cruel and unusual punishment; (3) Florida death penalty statute is not unconstitutional as applied to Defendant; and (4) counsel was not ineffective for failing to allege that Florida's capital sentencing statute is unconstitutional on its face and as applied to Defendant. View "Merck v. State" on Justia Law

At issue in this case was the constitutionality of certain provisions of chapter 2011-68, Laws of Florida, which converted the Florida Retirement System (FRS) from noncontributory by employees to contributory, required all current FRS members to contribute three percent of their salaries to the retirement system, and eliminated the retirement cost-of-living adjustment for creditable service after the effective date of the act. The circuit court held that the challenged amendments were unconstitutional, where the amendments violated three provisions of the Florida Constitution, and ordered Appellants - the governor, state board of administration, and the secretary of the department of management services - to reimburse all funds deducted or withheld pursuant to chapter 2011-68 from the compensation or cost-of-living adjustments of employees who were members of the FRS prior to the effective date of the act. The Supreme Court reversed, holding that the legislature did not violate the Florida Constitution in enacting the challenged provisions of chapter 2011-68. View "Scott v. Williams" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. The jury recommended a death sentence. Following a Spencer hearing, the trial court sentenced Defendant to death upon determining that the State had proven beyond a reasonable doubt the existence of several statutory aggravators. The Supreme Court affirmed the conviction and sentence, holding (1) the evidence presented at trial was sufficient to support the first-degree murder conviction; (2) under the totality of the circumstances, the death sentence in this case was proportionate; (3) Florida's protocol for execution by lethal injection is constitutional; and (4) Florida's capital sentencing process is constitutional. View "Kocaker v. State" on Justia Law

Defendant was originally convicted in 1981 for murder and sentenced to death. After a series of appeals and postconviction motions, Defendant filed a successive motion to vacate his sentence. Specifically, Defendant asserted that he was mentally retarded pursuant to Atkins v. Virginia. The trial court held an evidentiary hearing on Defendant's motion in 2009. The court denied relief, determining that Defendant could not meet the first prong of the mental retardation standard to establish his mental retardation. The Supreme Court affirmed, holding that there was competent, substantial evidence to support the court's finding that Defendant was not mentally retarded. View "Hall v. State" on Justia Law