Justia Constitutional Law Opinion Summaries

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.

Defendant appealed the postconviction court's order denying his motion filed pursuant to Florida Rule of Criminal Procedure 3.850 to vacate his first degree murder convictions and sentences of death. Defendant also petitioned the court for a writ of habeas corpus where defendant's convictions and sentences stemmed from the murder of his estranged wife, the murder of her parents, the burning of the parents' house with the victims' bodies still in it, and the theft of the wife's vehicle. Defendant raised nine guilt phase issues and three penalty phase issues on appeal. Defendant also filed a habeas corpus petition, raising six issues. The court addressed each issue and consequently affirmed the postconviction court's order denying defendant's rule 3.850 motion for relief and denied defendant's habeas petition.

Defendant appealed his three consecutive life sentences from convictions stemming from the armed robbery of an older couple in their home, followed by an incident involving a taxicab outside the couple's home shortly after the home invasion. At issue was whether the trial court improperly designated him as an habitual violent felony (HVFO) offender based on prior convictions that were entered on the same day. The court held that based on the statutory language of section 775.084, Fla. Stat., only one qualifying prior felony was required for an HVFO adjudication, and therefore it did not matter whether the qualifying prior felony conviction was adjudicated together with, or separate from, other felonies, so long as the qualifying felony conviction was entered separately from and prior to the current offense. Therefore, once the State established that defendant had one qualifying prior felony, he was properly sentenced as an HVFO and the court affirmed the district court's judgment.

Defendant, who was 22 years old at the time of the crime, was convicted of first degree murder, attempted armed robbery, and aggravated battery due to this role in the robbery of a coin laundry, which resulted in the shooting death of the victim. Defendant appealed his first-degree murder conviction and sentence of death. The court affirmed defendant's conviction after addressing his issues of error but vacated his death sentence because the court concluded that imposing a sentence of death would not be a proportionate punishment under the circumstances of the case. Accordingly, the court remanded for imposition of a sentence of life imprisonment without the possibility of parole.

Defendant appealed an order of the circuit court denying his amended motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.850 where he challenged his conviction of first degree murder and sentence of death and where he petitioned the court for writ of habeas corpus. Defendant raised twelve claims in his appeal from the denial of his rule 3.850 motion and also raised three claims in his petition for writ of habeas corpus. The court held that defendant's motion for postconviction relief was governed by rule 3.850 and his amended motion related back to the date of his original filing. With the single exception concerning this procedural claim, the court affirmed the postconviction court's denial of rule 3.850 and denied habeas relief.

Defendant pleaded guilty to burglary of a conveyance, grand theft of a quantity of mechanic's tools, and dealing in stolen property. Neither defendant or his counsel received notice that the State intended that he be sentenced as a habitual felony offender ("HFO") until, at the sentencing hearing, the State orally suggested that he qualified as an HFO. Defendant was then sentenced to concurrent terms of imprisonment and ordered to pay restitution to the victims. At issue was whether defendant's motion pursuant to Florida Rule of Criminal Procedure 3.800(b), claiming as sentencing errors the habitualization of the sentences without notice and insufficient evidence to support the amount of restitution ordered, properly preserved such errors. The court held that when, as in this instance, there was a clear sentencing error that affected the ultimate sanction imposed, it was cognizable under Rule 3.800(b). Accordingly, the court quashed that portion of the Second District's decision that reversed the trial court's order removing the HFO designation from defendant's sentence. The court held that the error complained of regarding the restitution order was not a sentencing error, but was one based on the sufficiency of the evidence that required a factual determination. Accordingly, it was not recognizable under Rule 3.800(b).

Defendant was convicted of grand theft and robbery with a firearm. At issue was whether defendant's dual convictions violated the prohibition against double jeopardy under paragraph (b) of Fla. Stat. 775.021(4)(b). The court held that subsection (b)(2) was inapplicable where a comparison of the elements of the crimes in this case demonstrated that each offense required an element of proof that the other did not. The court also held that subsection (b)(3) was also inapplicable because neither offense was wholly subsumed by the other and therefore, neither was a necessarily included offense of the other. Accordingly the court affirmed the convictions.

Defendant appealed his convictions for first degree murder and sentences of death. The most critical and dispositive issue in this case involved the denial of a motion to suppress statements that defendant contended were improperly obtained after police administered a Miranda warning, which defendant asserted was materially deficient because police failed to properly advise him that he had the right to counsel both before and during the custodial interrogation. The court concluded that the Miranda warnings reasonably conveyed to defendant his right to counsel because, given the context in which the police administered the warnings, the warnings provided a clear, understandable instruction that defendant had the right to counsel both before and during a custodial interrogation. Therefore,the court held that in light of Florida v. Powell, the court found that the Miranda warnings the police administered to defendant were sufficient. The court also rejected all other claims raised by defendant on appeal. Accordingly, the court affirmed defendants convictions and sentences.