Get above the noise
Log in for answers tailored to you — saved chats, your topics, and the full IJR suite.
Smith v. State
Supreme Court of Florida · 2011-10-06 · cited 10×
In Smith v. State, a defendant sentenced to death appealed the summary denial of his successive motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, raising claims of newly discovered evidence from FBI letters on comparative bullet lead analysis and a Brady violation involving undisclosed information about witness Priscilla Walker. The Florida Supreme Court reversed the postconviction court's denial and remanded for an evidentiary hearing on those two claims, finding them sufficiently pleaded. The court also directed the lower court to consider six additional Brady claims identified by the Eleventh Circuit in a cumulative materiality analysis under Kyles v. Whitley, as those involved suppressed favorable evidence that required further review. A partial dissent argued that the Brady claim regarding Walker was procedurally barred for failing to allege due diligence within the one-year time limit.
criminal lawprocedure
Harris v. State
Supreme Court of Florida · 2011-09-22 · cited 31×
In Harris v. State, the Florida Supreme Court considered whether a drug-detection dog's alert to the exterior of a vehicle supplies probable cause for a warrantless interior search, specifically examining the reliability of the dog Aldo after a traffic stop led to the discovery of pseudoephedrine pills. The court held that the State must establish the dog's reliability through a totality of the circumstances, requiring evidence beyond mere training and certification records, including field performance records, explanations of the certification process, the handler's training and experience, and any other objective indicators known to the officer. It quashed the First District Court of Appeal's decision affirming the search and disapproved contrary precedent from other districts while approving consistent rulings from the Second District. The reasoning centered on the lack of standardized training programs in Florida, the inability to cross-examine the dog, and the established burden on the State to prove probable cause for warrantless searches rather than shifting it to the defendant.
criminal lawcivil rights
Delgado v. State
Supreme Court of Florida · 2011-09-15 · cited 7×
In Delgado v. State, the Florida Supreme Court reviewed the conviction of Rogelio Delgado for kidnapping after he stole a truck containing a sleeping two-year-old child in the backseat, along with related charges of burglary and auto theft. The Court quashed the Third District Court of Appeal's decision affirming the kidnapping conviction and granted judgment of acquittal on that count. The core reasoning was that Florida's kidnapping statute under section 787.01(1)(a)2 requires the defendant to have knowledge of the victim's presence before or during the underlying felony, which the State failed to prove, and that the three-part test from Faison v. State was misapplied as it does not substitute for the statutory elements or expand liability.
criminal law
Williams v. Buss
Supreme Court of Florida · 2011-07-15
The case Williams v. Buss involved a request for relief that came before the Florida Supreme Court. The court dismissed the case after determining that relief was not authorized under existing law. It cited the precedent in Baker v. State, 878 So.2d 1236 (Fla. 2004), as the basis for this conclusion. All additional motions or requests for relief were also denied as part of the order. The decision was joined by five justices without noted dissent.
criminal lawprocedure
Bennett v. St. Vincent's Medical Center, Inc.
Supreme Court of Florida · 2011-07-07 · cited 28×
This case involved whether the parents of a severely brain-damaged infant born after a placental abruption and cesarean section could sue healthcare providers for medical malpractice in court or were limited to the no-fault administrative remedies under Florida's Birth-Related Neurological Injury Compensation Plan (NICA Plan). The Florida Supreme Court quashed the First District Court of Appeal's decision that had required the parents to pursue NICA compensation, holding instead that the infant did not suffer a "birth-related neurological injury" as defined by statute because the injury did not occur during labor, delivery, or immediate postdelivery resuscitation in the hospital. The court's reasoning centered on a narrow interpretation of the statutory phrase "immediate postdelivery period in a hospital" as modifying only the resuscitation period, rejecting an expansive view that would cover extended monitoring, and noting that the rebuttable presumption of NICA coverage did not apply since the parents were not seeking NICA benefits.
healthcareproceduretorts & liability
Ponton v. State
Supreme Court of Florida · 2011-06-30 · cited 3×
The case involved Gregory Ponton challenging his designation as a habitual violent felony offender (HVFO) under Florida law, arguing that his prior convictions from the same day did not qualify as sequential for the HVFO sentencing enhancement. The Florida Supreme Court held that the HVFO statute requires only one qualifying prior felony conviction separate from the current offense, and multiple prior felonies adjudicated on the same day can still serve as predicates. The court reasoned from the plain language of section 775.084, Florida Statutes (1993), which does not impose a sequential conviction requirement for HVFO designations. Accordingly, the court approved the Third District Court of Appeal's affirmance of Ponton's sentence and disapproved the conflicting Second District decision in Rutherford v. State.
criminal law