Justia Constitutional Law Opinion Summaries

Defendant appealed his conviction for first degree murder and his death sentence. In his direct appeal, defendant raised twelve issues challenging the effectiveness of his trial counsel and various rulings and conclusions made by the trial court at both the guilt and sentencing phases, including an issue regarding the proportionality of the death sentence. Defendant also challenged the constitutionality of Florida's capital sentencing scheme. After reviewing the issues brought on appeal and conducting the court's own independent review of the sufficiency of the evidence, the court affirmed defendant's convictions for first degree murder, burglary with a battery while armed with a firearm, animal cruelty, grant theft of a motor vehicle, and grant theft of a firearm and the sentences imposed for these offenses.

The facts in this case arose from an arrest after the driver failed a roadside sobriety test and then had her license suspended based on the refusal to submit to a breath test. The court was asked to answer two certified questions: (1) "Does a law enforcement officer's request that a driver submit to a breath, blood, or urine test, under circumstances in which the breath-alcohol test is the only required test, violate the implied consent provisions of section 316.1932(a)(A)(1)(a) such that the department may not suspend the driver's license for refusing to take any test?" and (2) "May a district court grant common law certiorari relief from a circuit court's opinion reviewing an administrative order when the circuit court applied precedent from another district court but the reviewing district court concludes that the precedent misinterprets clearly established statutory law?" The court answered the first certified question in the negative. The Second District properly found that there was no violation of the implied consent law under the circumstances of this case. Accordingly, the court approved the Second District's decision and disapproved the Fourth district's opinion in State Department of Highway Safety and Motor Vehicles v. Clark to the extent that it concluded to the contrary. The court answered the second question in the affirmative and held that a district court could exercise its discretion to grant certiorari review of a circuit court decision reviewing an administrative order, so long as the decision under review violated a clearly established principle of law resulting in a miscarriage of justice, even if the circuit court decision was based on precedent from another district.

Defendant was found guilty of first-degree felony murder, second-degree murder, and aggravated child abuse. At issue was whether the merger doctrine precluded a first-degree felony-murder conviction predicated on a single act of aggravated child abuse that caused the child's death. Based upon legislative intent as evidenced by the plain language of the felony-murder statute, the court held that the merger doctrine did not preclude a felony-murder conviction predicated upon a single act of aggravated child abuse that caused the child's death. Accordingly, the court answered the certified question in the negative, receded from Brooks v. State to the extent that it held to the contrary, and quashed the First District's decision,

This case arose when defendant was arrested and charged in county court with the misdemeanor offenses of possessing marijuana, possessing drug paraphernalia, and driving under the influence. Defendant filed a motion to suppress all evidence obtained during the search that followed the stop, claiming that the stop was illegal because it was not based upon probable cause that she had committed a traffic infraction. At issue was the application of the fellow officer rule to testimony in a motion to suppress hearing where defendant was challenging the validity of the traffic stop. The court held that the fellow officer rule did not allow an officer who did not have firsthand knowledge of the traffic stop and was not involved in the investigation at the time to testify as to hearsay regarding what the initial officer who conducted the stop told him or her for the purpose of proving a violation of the traffic law so as to establish the validity of the initial stop. Therefore, the court disapproved of the Fourth district in Ferrer v. State and approved the decision of the Second District in Bowers v. State.

Defendant was convicted of first-degree murder and sentenced to death for his role in the 1987 killing of a correctional officer. Defendant subsequently appealed the circuit court's summary denial of his second successive motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.851. Because defendant's claim originated from information that existed as early as this court's issuance of its direct-appeal decision in 1990, and because the juror affidavits at issue in this case related to matters that inhered in the verdict, the court affirmed the circuit court's denial of this claim as both untimely and based upon inadmissible evidence.

This case was before the court on appeal from a judgment of conviction of first degree murder and a sentence of death. The court held that the trial court properly limited the cross-examination of a State witness; the trial court did not abuse its discretion in overruling defense counsel's objection and denying a mistrial based upon the prosecution's statement; the trial court did not abuse its discretion in admitting the 47 shell casings into evidence along with the other evidence to which they related; the trial court properly declined to conduct a Frye hearing on tool-mark identification; the trial court did not err in accepting the State's explanation for exercising a peremptory strike to remove a minority juror; and the death sentence was proportionate where, in addition to murdering the victim, defendant also kidnapped her from her home and raped her. Accordingly, the convictions and sentences were affirmed.

Defendant, a prisoner under sentence of death, appealed the denial of his successive motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.851. Defendant asserted a destruction of evidence claim and Brady v. Maryland claim. The court affirmed the circuit court's denial of postconviction relief. Further, the court rejected the State's cross-appeal and affirmed the determination of the postconviction court that defendant's second claim satisfied the due diligence component of Rule 3.851(d)(2)(A). No motion for rehearing would be entertained by this court. The mandate should issue immediately. Defendant's request for a stay of execution was denied.

Defendant appealed his conviction for first degree murder and his sentence of death. Defendant claimed that the trial court erred by instructing the jury on finding the heinous, atrocious, or cruel (HAC) aggravator for the murder of the victim and that defendant's death sentence was disproportionate. The court held that the jury instruction on the aggravator was not error when the victim was attending a party, defendant stormed in and demanded money with the threat of firing his AK-47, shot the victim multiple times, and the victim eventually died from the gunshot wounds. The court also concluded that the trial court did not err in finding the HAC aggravator because it was supported by competent substantial evidence. Considering the circumstances, the aggravating and mitigating factors weighed by the trial court, and other cases with similar facts, the court concluded that defendant's death sentence was proportionate. Further, the competent substantial evidence presented at trial was sufficient to support defendant's conviction. Therefore, the judgment was affirmed.

The North Port Road and Drainage District (NPRDD), a municipal dependent special district wholly contained within the City of North Port, levied non-ad valorem special assessments against nine parcels of real property owned by West Villages Improvement District, an independent special district of the State of Florida. The Second District held that NPRDD could not lawfully impose the special assessments on West Villages' real property without statutory authority. The court affirmed, but on the basis that NPRDD's home rule power under the Florida Constitution did not reach as far as it argued. Accordingly, because there was no way for West Villages to lawfully pay the special assessments, NPRDD's assessments fell within the limitations on home rule powers set forth in section 166.021(3), Florida Statutes.

Raymond Bright was convicted of two counts of first-degree premeditated murder and sentenced to death for the murders. The Supreme Court affirmed the convictions and sentences, holding (1) sufficient evidence existed in the record for the jury to convict Bright of first-degree premeditated murder; (2) the prosecutor did not improperly comment on Bright's right to remain silent, and the trial court did not abuse its discretion when it denied Bright's motion for a mistrial; (3) the trial court erred when it found and weighed as two separate aggravating circumstances Bright's prior felony conviction, but the improper double finding of the prior violent felony aggravating circumstance constituted harmless error; (4) the trial court did not abuse its discretion in finding and affording the aggravating circumstance that the murder was especially heinous, atrocious, or cruel, great weight; and (5) the sentences imposed by the trial court were proportionate.