Justia Constitutional Law Opinion Summaries

Defendant appealed an order entered by the circuit court finding him competent to be executed. Defendant's primary argument on appeal was that the circuit court improperly found him sane to be executed based on its finding that his delusions were a manifestation of a normal Christian belief, and alternatively, that the circuit court's determination was a misapplication of the standard pronounced in the United States Supreme Court's decision in Panetti v. Quarterman. The Supreme Court affirmed the circuit court's order finding Defendant sane to be executed, holding (1) there was competent, substantial evidence to support the circuit court's determination that Defendant was sane to be executed; (2) Defendant's argument concerning Panetti was without merit; and (3) Defendant's due process claims were without merit. View "Ferguson v. State" on Justia Law

Appellant, a prisoner under sentence of death, appealed the circuit court's order denying his second successive motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851 and the order denying his motion for competency determination. The Supreme Court affirmed, holding (1) Appellant's claim that Florida's lethal injection statute violates the Separation of Powers Doctrine was time-barred; (2) the circuit court properly found Appellant's claim that the clemency proceeding did not comport with due process was time-barred; (3) the circuit court properly denied Appellant's claim that, as applied, Florida's death warrant selection process was unconstitutional; (4) Appellant's argument that his punishment was unconstitutional because he was incarcerated on death row for over three decades failed; and (5) the circuit court did not err in denying Appellant's motion for competency determination. View "Ferguson v. State" on Justia Law

This case was before the Supreme Court on appeal from a judgment of conviction of first-degree murder and a sentence of death. The Supreme Court affirmed Appellant's conviction but remanded for a new penalty phase, holding, inter alia, (1) the trial court erred in admitting certain testimony from Appellant's wife, as the communications reflected in the testimony were privileged, but the error was harmless beyond a reasonable doubt; (2) the trial court should have granted Appellant's motion for judgment of acquittal on the charge of attempted sexual battery, but the error did not require a new trial; (3) the trial court's finding of the cold, calculated, and premeditated aggravator was error; and (4) based on the number of errors during the penalty phase, the errors were not harmless. View "Kaczmar v. State" on Justia Law

Petitioner, a juvenile placed on juvenile probation, pleaded guilty to failing to follow an order of probation by violating curfew and failing to obey household rules. The circuit court then placed Petitioner in secure detention. Petitioner subsequently filed a petition for writ of habeas corpus, arguing that his sentence was illegal. The second district court of appeal denied Petitioner's petition for writ of habeas corpus and certified conflict with the fifth district court of appeal's decision in M.P. v. State. The Supreme Court (1) approved the decision of the second district court of appeal denying Petitioner's petition for writ of habeas corpus, and (2) disapproved the decision of the fifth district court of appeal in M.P. to the extent it was inconsistent with this opinion. View "J.M. v. Gargett" on Justia Law

In 2005, Petitioner was convicted and sentenced for committing two sex offenses. Since 2009, Petitioner, an inmate in state custody, had filed six previous extraordinary writ petitions with the Supreme Court seeking various forms of relief related to his convictions or sentences. Each of Petitioner's extraordinary writ petitions filed with the Supreme Court was devoid of merit or inappropriate for consideration. Therefore, the Court issued an order directing Petitioner to show cause why he should not be prohibited from filing any subsequent pro se filings in the Court regarding his convictions. After considering Petitioner's response, the Court concluded that it failed to show cause why sanctions should not be imposed. In the meantime, Petitioner filed a pro se petition for writ of habeas corpus with the Supreme Court alleging that his sentences were illegal. The Court further concluded that Petitioner's procedurally barred petition filed in this case was a frivolous proceeding brought before the Court by a state prisoner, and accordingly, the Clerk of Court was instructed to reject any future pleadings, petitions, motions, documents, or other filings submitted by Petitioner regarding his convictions. View "Green v. Tucker" on Justia Law

This case was before the Supreme Court on a property appraiser's appeal of the court of appeal's decision affirming a circuit court's grant of an ad valorem homestead tax exemption to David and Ana Andonie (the taxpayers) and declaration that a portion of Fla. Stat. 196.031(1) was invalid and unenforceable because the statutory provision limited the class of property owners otherwise eligible for ad valorem tax relief under Fla. Const. art. VII, 6(a). The Court affirmed the decision of the court of appeal to the extent it was consistent with its holding here, holding (1) the plain language of article VII, section 6(a) permits every owner of Florida real property to apply for and receive ad valorem tax relief where it is sufficiently demonstrated that the owner has maintained on that property the permanent residence of another legally or naturally dependent on the owner; and (2) the property appraiser here failed to sufficiently preserve for appellate review any argument regarding the sufficiency of the evidence introduced in the circuit court below, and the record sufficiently demonstrated that the taxpayers maintained on their property the permanent residence of their minor children, each of whom was legally and naturally dependent on the taxpayers. View "Garcia v. Andonie" on Justia Law

After a jury trial, Petitioner was convicted of first-degree murder, second-degree murder, and burglary of a dwelling during which a battery upon the victims was committed while Petitioner was armed with a weapon. The trial court sentenced Petitioner to death for the first-degree murder convictions. Petitioner subsequently filed a motion to vacate his convictions of first-degree murder and sentences of death under Fla. R. Crim. P. 3.851. The circuit court denied the motion. Petitioner appealed and petitioned the Supreme Court for a writ of habeas corpus. The Court affirmed the denial of the Rule 3.851 motion, and denied Petitioner's petition for a writ of habeas corpus, concluding that no reversible error occurred and that defense counsel did not perform ineffectively. View "Reynolds v. Tucker" on Justia Law

Appellant was a prisoner under sentence of death. After the Supreme Court affirmed Appellant's death sentence on direct appeal. D. Todd Doss was appointed as counsel for Appellant for Appellant's postconviction proceedings. Thereafter, Appellant sought to discharge Doss as postconviction counsel and waive the postconviction proceedings. The circuit court found Appellant competent and issued an order discharging Doss and dismissing the proceedings. Doss, on behalf of Appellant, appealed. The Supreme Court affirmed, holding (1) Appellant was afforded constitutionally adequate competency, waiver of postconviction, and discharge of counsel proceedings; and (2) the circuit court did nor err in finding Appellant competent to waive postconviction proceedings and to discharge counsel. View "Gill v. State" on Justia Law

Appellant was convicted of first-degree murder, false imprisonment as a lesser included offense of kidnapping, armed robbery with a deadly weapon, and grand theft of a motor vehicle. A jury recommended a sentence of death. The trial court accepted that recommendation and sentenced Appellant to death. The Supreme Court affirmed the findings and underlying judgment of guilty in the trial court but reversed and remanded for the limited purpose of requiring the trial court to perform a new sentencing evaluation because the analysis of the mitigating circumstances in the trial court's sentencing order did not meet the requirements articulated in Campbell v. State. View "Oyola v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and armed robbery and sentenced to death. The Supreme Court affirmed Appellant's convictions and sentence, holding (1) Appellant's statement to police was properly admitted into evidence, and police did not violate the Fifth Amendment in obtaining the statement; (2) Appellant's confession was voluntary, and contrary to Appellant's contention, the confession was not coerced by detectives; (3) the trial court did not err in finding the aggravating factor of cold, calculated, and premeditated to be established in Appellant's capital murder prosecution; (4) the trial court did not err in finding that Appellant did not prove the mitigating factors of emotional abuse, sexual abuse, and remorse; (5) the trial court did not overlook any material evidence in considering the aggravating and mitigating factors; (6) Appellant's constitutional challenge to Florida's death sentencing scheme was without merit; (7) Appellant's sentence of death was proportionate; and (8) there was sufficient evidence to support Appellant's convictions. View "Martin v. State" on Justia Law