Justia Constitutional Law Opinion Summaries

The State charged Defendant, who at the time was detained at a juvenile detention center, with one count of battery by detainee in violation of Fla. Stat. 784.03 and 784.082. Defendant moved to dismiss the charge, contending that a juvenile could not be lawfully charged with battery by detainee while detained in a juvenile detention facility. The trial court dismissed the charge based on its belief that it was bound to follow the first district court of appeal's decision in T.C. v. State, which held that the battery by detainee offense was inapplicable to juveniles held in juvenile facilities. The fourth district court of appeals reversed, noting that in the past it and the fifth district had affirmed a trial court order adjudicating a juvenile guilty of battery upon a fellow detainee. The Supreme Court affirmed, holding that a juvenile detention center qualifies as a "detention facility" for purposes of section 784.082, and thereby disapproving the first district's decision in T.C.

Petitioner was convicted of the 1999 sexual battery and first-degree murder of an eighteen-year-old and sentenced to death. The Supreme Court affirmed his convictions and sentences. Petitioner subsequently appealed the denial of his motion for postconviction relief filed pursuant to Fla. R. Crim. P. 3.851 and simultaneously petitioned for a writ of habeas corpus. The Supreme Court affirmed the postconviction court's denial of relief and denied Petitioner's habeas petition, holding (1) Defendant failed to carry his burden of demonstrating he was prejudiced by trial counsel's deficient performance in preparation for the penalty phase; (2) Rule 3.851, which imposes a one-year time limit for filing motions for postconviction relief, is not unconstitutional; (3) Florida's capital sentencing statute is not unconstitutional; and (4) certain omissions by his appellate counsel on direct appeal did not constitute ineffective assistance of appellate counsel.

Defendant was charged with second-degree murder and was convicted as charged. The court of appeal affirmed. Defendant subsequently petitioned for writ of habeas corpus, arguing that his appellate counsel was ineffective for failing to raise a claim of fundamental error when the jury was instructed on manslaughter by intentional act as a lesser included offense. The third district court of appeal certified conflict with the decision of the first district court of appeal in Montgomery v. State. The Supreme Court stayed proceedings pending disposition of Montgomery. In Montgomery, the Court held that the use of the then-standard jury instruction on the lesser included offense of manslaughter by act constituted fundamental error in Montgomery's case because the instruction erroneously required the jury to find that the defendant intentionally caused the death of the victim. After the Court lifted the stay in the instant case, the Court quashed the decision under review and remanded the matter to the court of appeal for reconsideration upon application of its decision in Montgomery.

Defendant Joshua Lee Altersberger pled guilty to the first-degree murder of Florida Highway Patrol Sergeant Nick Sottile. The jury found two aggravating circumstances beyond a reasonable doubt: the murder was committed in a cold calculated, and premeditated manner; and the victim was a law enforcement officer engaged in the lawful performance of his official duties. The trial court followed the jury's recommendation and sentenced Defendant to death. Defendant appealed. The Supreme Court affirmed Defendant's conviction and sentence, holding (1) the trial court did not err in its finding that Sergeant Sottile's murder was cold, calculated, and premeditated; (2) Defendant's plea was knowingly, intelligently, and voluntarily entered into; and (3) the death penalty was proportionate in this case.

Defendant was convicted of the first-degree murder of Officer Donna Fitzgerald. Fitzgerald's body was found in the paint room at Tomoka Correctional Institute (TCI). After Defendant, an inmate at TCI, was apprehended by TCI personnel, Defendant repeated, "I freaked out. I snapped. I killed her." The trial court imposed the sentence of death. The Supreme Court affirmed Defendant's conviction and sentence, holding (1) the trial court properly denied Defendant's motion to suppress his confessions; (2) the trial court did not err in admitting opinion testimony of the medical examiner regarding the sequence of wounds and position of the victim; (3) the trial court's finding of a certain aggravator was in error, but the error was harmless; (5) the death sentence was appropriate; and (6) Florida's death sentencing scheme is not unconstitutional under Ring v. Arizona.

Convicted of first-degree murder for causing the 2007 death of McKinness, Hampton was sentenced to death following the jury’s recommendation by a vote of nine to three. Hampton filed several motions seeking relief based on the allegation that one of the jurors was “under prosecution” at the time of his jury service. The trial court denied the motions. The Florida Supreme Court affirmed the conviction and sentence, rejecting challenges to the sufficiency of the evidence and the proportionality of the death sentence.

Section 893.13 of the Florida Comprehensive Drug Abuse Prevention and Control Act, provided that “it is unlawful for any person to sell, manufacture, or deliver, or possess with intent to sell, manufacture, or deliver, a controlled substance… or … to be in actual or constructive possession of a controlled substance.” The law did not specify the mental state required for conviction. In prior decisions, the Florida Supreme Court determined that knowledge of the presence of the substance and knowledge of the illicit nature of the substance were required. In response, the Legislature, in 2011, stated that the decisions were contrary to legislative intent. “The Legislature finds that knowledge of the illicit nature of a controlled substance is not an element of any offense under this chapter. Lack of knowledge of the illicit nature of a controlled substance is an affirmative defense.” The statute does not eliminate the element of knowledge of the presence of the substance. Since the enactment, each court of appeal has ruled that the statute does not violate requirements of due process. The U.S. District Court (M.D. Fla.) concluded, however, that it is unconstitutional. Based on that decision, a trial court dismissed a case under the Act. The Florida Supreme Court reversed.

Defendant was sentenced to death for a drug-related 1988 murder. The Florida Supreme Court reversed the circuit court's denial of post-conviction relief based on a claim of ineffective assistance of counsel during the penalty phase. Counsel rendered ineffective assistance by failing to investigate, develop, and present available mitigating evidence that would have legally precluded the trial court from overriding the jury's life recommendation. The evidence in question concerned the abuse defendant endured at the hands of his father and the extremely negative influence his father had on his life and that from a young age he witnessed violent acts being committed against his mother and others, including witnessing others being killed.

Delhall, was convicted of first-degree premeditated murder, unlawful use of a firearm, unlawful discharge of the firearm resulting in death or serious bodily harm, and possession of a firearm by a convicted felon. At the jury trial the State presented evidence that Delhall murdered the victim because he was, at that time, the only known eyewitness to the murder of another individual (Bennett) with which Delhall’s brother was charged. The jury recommended a death sentence by a vote of eight to four, and the trial court entered an order sentencing Delhall to death. The Florida Supreme Court vacated the sentence, stating that the prosecutor, “by her overzealous and unfair advocacy, appeared to be committed to winning a death recommendation rather than simply seeking justice.” Her improper advocacy continued even after an objection was sustained. In one instance, the judge was forced to step in and specifically admonish her to stop it. Cumulative errors fundamentally tainted the guilt phase, which was especially significant in view of the fact that the jury recommended death by a vote of eight to four, a recommendation that was far from unanimous.

Butler was convicted of first-degree murder and sentenced to death for the 1997 murder of his former girlfriend. The Florida Supreme Court affirmed the conviction and death sentence on direct appeal. Butler filed a motion to vacate his conviction and death sentence pursuant to Florida Rule of Criminal Procedure 3.851. The post-conviction court held three evidentiary hearings and denied relief. The Florida Supreme Court affirmed, rejecting claims that appellate counsel provided ineffective assistance by failing to file a petition for certiorari with the U.S. Supreme Court; appellate counsel provided ineffective assistance by abandoning the claim that a witness was incompetent to testify at trial; Florida’s lethal injection protocol constitutes cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments; and Butler’s right against cruel and unusual punishment will be violated because he may be incompetent at the time of execution.