Justia Constitutional Law Opinion Summaries

Defendant, a prisoner under sentence of death, appealed an order of the circuit court denying his initial motion under Florida Rule of Criminal Procedure 3.851 to vacate his conviction of first-degree murder and sentence of death and petitioned the court for a writ of habeas corpus. On appeal, defendant raised the following claims: (A) trial counsel was ineffective for failing to develop and present mitigation; (B) trial counsel was ineffective for failing to file a motion to suppress his confession; (C) trial counsel was ineffective for failing to have the jury view the entire confession tape; (D) trial counsel was ineffective in the guilt phase; (E) the postconviction court violated defendant's right to due process by summarily denying several claims; (F) the postconviction court erred in denying claims regarding the testimony of the fingerprint examiner; (G) the postconviction court erred in denying defendant's claim that the State committed a Brady violation by not conducting promised blood testing; (H) cumulative error deprived defendant of a fair trial; and (I) defendant may be incompetent to be executed. The court addressed each claim and subsequently affirmed the postconviction court's order denying relief and denied the habeas petition.

Defendant was convicted and sentenced to death for murder. Defendant subsequently appealed the denial of his motion for postconviction relief under Florida Rule of Criminal Procedure 3.851. Defendant claimed that his counsel rendered ineffective assistance in the penalty phase, that the State withheld favorable information, that the State made a false statement during trial, and that the postconviction court erred during the evidentiary hearing. The court concluded that defendant's counsel was deficient for stipulating to the admissibility of a statement defendant made to law enforcement on May 7, 1982. The court also concluded that the State withheld favorable information, specifically the complete terms of a cooperation agreement with a codefendant. The court concluded, however, that because defendant failed to demonstrate prejudice on these claims and his remaining claims were without merit, the judgment was affirmed.

Defendant was convicted on three counts of first-degree murder and sentenced to death on each count. Defendant appealed an order denying a second successive motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, claiming that he was deprived of effective trial counsel during the penalty phase because that phase was conducted before a jury that returned a death recommendation in violation of Porter v. McCollum. The court held that the trial level postconviction court properly denied defendant's second successive postconviction motion because the decision in Porter did not constitute a fundamental change in the law that mandated retroactive application under Witt v. State. Therefore, the court affirmed the judgment.

Defendant appealed his conviction of first degree murder and sentence of death. Defendant raise six claims on appeal: (A) the trial court erred in denying several motions in limine; (B) the trial court erred in admitting the testimony of a DNA analyst from defendant's first trial; (C) the trial court erred at the guilt phase in denying the jury's request to view the indictment or have the indictment read to them; (D) the trial court erred at the penalty phase by providing improper instructions to the jury; and (E) the death sentence was not proportionate. The court held that none of these claims warranted relief and affirmed defendant's conviction and sentence.

Defendant, a prisoner under sentence of death, appealed the denial of his amended and supplemental motions for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.850. Defendant raised the following claims on appeal: (1) the postconviction court erred in denying his claims pertaining to comparative bullet lead analysis (CBLA) and certain testimony; (2) trial counsel rendered ineffective assistance of counsel during the penalty phase; (3) trial counsel was ineffective in failing to object to the introduction of gruesome photographs; (4) defendant's rights were violated when he was improperly shackled during his trial; (5) Florida Rule of Criminal Procedure 3.852 was unconstitutional; (6) the penalty-phase jury instructions were unconstitutional; and (7) Florida's death penalty statute was unconstitutional. The court summarily denied claims 3, 4, and 6 as insufficiently pled. The court also denied without discussion of defendant's challenge pertaining to rule 3.852, based on the reasoning the court employed in ruling on his claim in defendant's postconviction appeal relating to the Domino's Pizza murders. The court further denied claim 7, challenging the constitutionality of the death penalty, based on the court's well-established precedent. Defendant had not made any additional allegations that would call into question the State's current methods of execution. Accordingly, the court affirmed the postconviction court's denial of relief and also denied defendant's habeas petition.

Petitioner, an inmate in state custody, filed a pro se petition for writ of mandamus with the court. Petitioner's petition was the twenty-seventh notice of extraordinary writ petition he had filed with the court since 2000. The court held that, because petitioner abused the limited judicial resources of the court, sanctions were warranted.

Defendant, a prisoner under sentence of death, appealed the denial of his motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.851. In the instant appeal, defendant primarily criticized his counsel's performance at trial for failing to adequately challenge the State's circumstantial case. Defendant argued that counsel rendered ineffective assistance for stipulating to the fact that DNA matching the victim's DNA was derived from blood as opposed to some other source. Defendant also contended that counsel was ineffective for failing to retain and call an expert to challenge the State's scratch-marks expert. Defendant additionally challenged counsel's presentation of mental health mitigation during the penalty phase. After conducting an evidentiary hearing, the postconviction court denied relief on these claims, as well as summarily denying relief on defendant's challenge to the rules prohibiting juror interviews. The court affirmed the postconviction court's denial of all claims.

Petitioner was convicted of several crimes, including the kidnapping of his eleven-year-old son. At issue was whether a parent could lawfully be convicted of kidnapping his own child under section 787.01, Florida Statutes. The court held that the plain language of section 787.01 did not preclude a parent from being held criminally liable for kidnapping his or her own child.

Defendant, a prisoner under sentence of death, appealed from a circuit court order denying postconviction relief in this capital case. At issue was the court's procedure regarding the issue of pro se representation by defendants in capital postconviction appeals. Based on its solemn duty to ensure that the death penalty was imposed in a fair, consistent, and reliable manner, as well as the court's administrative responsibility to work to minimize the delays inherent in the postconviction process, the court held that death-sentenced defendants could not appear pro se in postconviction appeals. Accordingly, defendant's motion to discharge counsel and appear pro se and appellate counsel's motion for leave to withdraw were denied.

Defendant shot and killed a convenience store clerk during a robbery and was subsequently tried and convicted of armed robbery and first degree murder. At issue was whether the facts supported the trail court's legal conclusion that defendant had established the first prong of the mental retardation standard, i.e. significantly subaverage general intellectual functioning. The court held that the circuit court erred as a matter of law in finding that defendant met the definition of mental retardation under Florida law and therefore vacated the circuit court's order granting defendant's postconviction motion.