Justia Constitutional Law Opinion Summaries

Defendant was convicted of two counts of first-degree murder for the stabbing deaths of his cousin's girlfriend and her four-year-old daughter. Defendant appealed his convictions and sentences of death. The court held that the trial court did not abuse its discretion in denying defendant's motion for mistrial and in finding no discovery violations. The court also held that there was no basis that would disqualify the jury from rendering a penalty recommendation. The court rejected defendant's challenge to the constitutionality of Florida's death sentencing scheme. The court further held that the record demonstrated that there was competent, substantial evidence to sustain defendant's convictions. The court finally held that based on the evidence set forth, the aggravators the trial court found, and the totality of the circumstances, defendant's death sentences were proportionate compared to other death sentences the court had upheld. Accordingly, the court affirmed the convictions and sentences.

Defendant was convicted of the first-degree shooting murder of a deputy sheriff, the attempted murder of another deputy sheriff, and armed robbery. Defendant was sentenced to death. Both defendant and the State raised issues on appeal. The court held that the trial court did not abuse its discretion in admitting photographic evidence and a vial of blood; in admitting a bullet fragment into evidence; and in failing to instruct the jury that defendant was not guaranteed parole at or after 25 years. The court also held that, because defendant failed to demonstrate that any of his claims amounted to error, defendant's claim of cumulative error was denied. The court finally held that, when compared with other capital cases, the death sentence in defendant's case was proportionate.

Twenty-six Florida counties and the Florida Association of Counties filed suit seeking a declaratory judgment that section 19 of the Laws of Florida (Act) was unconstitutional. The district court affirmed the trial court's decision and held that section 19 of the Act unconstitutionally shifted the responsibility to fund certain costs of court-appointed counsel from the state to the counties in violation of article V, section 14, of the Florida Constitution and that section 19 was unconstitutional based on the Legislature's failure to make the constitutionally required determination of an important state interest, as provided by article VII, section 18(a) of the constitution. The court agreed with the district court and the circuit court that the plain language of article V, section 14 provided that the state was responsible for funding the Offices of Criminal Conflict and Civil Regional Counsel (RCC), including the overhead costs outlined in subsection (c). The court held that, based on its determination that the district court correctly held that section 19 was unconstitutional under article V, section 14, the court concluded that it was unnecessary to address whether section 19 violated article VII, section 18(a) of the constitution.

Defendant appealed his conviction of first-degree murder and sentence of death. The court held that the trial court did not abuse its discretion in accepting defendant's request to waive the presentation of mitigation during the penalty phase where the trial court complied with the three-part procedure in Koon v. Dugger and complied with the Muhammad v. State requirements. The court also affirmed the trial courts finding of cold, calculated, and premeditated (CCP) and especially heinous, atrocious, or cruel (HAC) aggravators. The court court further held that because the trial court did not abuse its discretion, the court would not reweigh the trial court's assignment of weight. Therefore, the court held that defendant's death sentence was proportionate. The court finally held that a review of the record revealed that defendant's plea was made knowingly, intelligently and voluntarily. Therefore, the plea and conviction were properly entered. Further, the factual basis for the plea, which was confirmed by defense counsel and defendant, and was proven by the forensic evidence and defendant's confessions, provided competent, substantial evidence to support the conviction and sentence.

Defendant was convicted of trafficking in cocaine and sale or possession of cocaine within 1000 feet of a church. At issue was whether the trial judge's arbitrary policy of rounding up sentences constituted a due process violation that was fundamental error reviewable on appeal without contemporaneous objection. The court held that the sentence imposed was within the legal guidelines - it was above the minimum required by the scoresheet and below the statutory maximum, but the trial judge's stated policy "improperly extended" defendant's incarceration in an arbitrary manner. Therefore, because this policy of "rounding up" violated defendant's right to due process, the court quashed the decision and remanded with directions that the trial court be directed to enter a sentence at the bottom of the guidelines and consistent with the reasoning expressed.

Appellant, a prisoner under sentence of death, appealed the denial of his amended successive motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.851. Defendant raised numerous claims, including an Eighth Amendment challenge to the Florida Department of Correction's (DOC) lethal injection protocol, which replaced the first drug in its three-drug sequence, sodium thiopental, with another drug, pentobarbital sodium. The court held that, after reviewing the evidence and testimony, appellant had failed to satisfy the "heavy burden" that Florida's current lethal injection procedures, as implemented by the DOC, were constitutionally defective in violation of the Eighth Amendment. The court affirmed the circuit court's orders and vacated the temporary stay on execution.

This case was before the court on the petition of Rosalie Whiley for a writ of quo warranto seeking an order directing the Governor of the State of Florida to demonstrate that he had not exceeded his authority, in part, by suspending rulemaking through Executive Order 11-01. The court granted relief and held that the Governor impermissibly suspended agency rulemaking to the extent that Executive Orders 11-01 and 11-72 included a requirement that the Office of Fiscal Accountability and Regulatory Reform (OFARR) must first permit an agency to engage in the rulemaking which had been delegated by the Florida Legislature. Absent an amendment to the Administrative Procedure Act, 5 U.S.C. 500 et seq., itself or other delegation of such authority to the Governor's office by the Florida Legislature, the Governor had overstepped his constitutional authority and violated the separation of powers.

Defendant was convicted of first degree murder, armed burglary, attempted sexual battery, and armed robbery, and sentenced to death. Defendant appealed the circuit court's denial of his motion to vacate his conviction and sentence under Florida Rule of Criminal Procedure 3.851, raising eleven claims. Defendant also filed a petition for writ of habeas corpus, raising nine claims. The court discussed and disposed of each claim and subsequently affirmed the circuit court's judgment and denied defendant's habeas petition.

Defendant was convicted of first-degree murder of his step-daughter and sentenced to death. At issue was whether the trial court erred in admitting collateral crime evidence; whether the trial court erred in finding the cold, calculated, and premeditated (CCP) aggravator; and whether the death sentence was proportionate. The court held that the collateral crime evidence that defendant was engaged in an illegal sexual relationship with his stepdaughter's minor daughter was relevant to establish motive and inextricably intertwined with the testimony of the chain of events. The court also held that the CCP aggravator was supported by competent, substantial evidence. The court held, however, that the death penalty was disproportionate in light of the circumstances and in light of three statutory mitigating factors: (1) the defendant was under the influence of extreme mental or emotional disturbance at the time the capital felony was committed; (2) the capacity of defendant to appreciate the criminality of his conduct or conform his conduct to the requirements of law was substantially impaired; and (3) the age of the defendant. Accordingly, the court confirmed the conviction but vacated the sentence of death and reduced defendant's sentence to life imprisonment without the possibility of parole.

The State sought review of the district court's reversal of defendant's convictions for possession of cocaine for sale. At issue was whether the district court erred in refusing to consider the State's argument on appeal that the evidence was legally discovered following a proper investigatory stop because the theory had not been raised in the trial court. The court held that the Fourth District's refusal to consider the state's theory expressly and directly conflicted with Dade County School Board v. Radio Station WQBA, which held that "an appellee, in arguing for the affirmance of a judgment, is not limited to legal arguments expressly asserted as grounds for the judgment in the court below." Therefore, the court concluded that the Fourth District properly determined that the factual circumstances of the case supported the trial court's conclusion that police officers had probable cause to search defendant. Accordingly, the Fourth District's decision was quashed.