Joshua Davis v. State of Florida

CourtSupreme Court of Florida
DecidedSeptember 8, 2022
DocketSC20-1282
StatusPublished

This text of Joshua Davis v. State of Florida (Joshua Davis v. State of Florida) is published on Counsel Stack Legal Research, covering Supreme Court of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joshua Davis v. State of Florida, (Fla. 2022).

Opinion

Supreme Court of Florida ____________

No. SC20-1282 ____________

JOSHUA DAVIS, Petitioner,

vs.

STATE OF FLORIDA, Respondent.

September 8, 2022

COURIEL, J.

We have for review the decision in Davis v. State, 311 So. 3d

927 (Fla. 2d DCA 2020), in which the Second District Court of

Appeal certified the following question of great public importance:

WHEN A DEFENDANT IN A CRIMINAL CASE ASSERTS IN AN APPEAL FROM A JUDGMENT AND SENTENCE THAT THE TRIAL COURT ERRONEOUSLY DENIED A LEGALLY SUFFICIENT MOTION TO DISQUALIFY THE TRIAL JUDGE FOR ALLEGED BIAS OR PREJUDICE UNDER SECTION 38.10, FLORIDA STATUTES (2015), AND FLORIDA RULE OF JUDICIAL ADMINISTRATION 2.330(D)(1), SHOULD AN APPELLATE COURT REVIEW THE ERRONEOUS DENIAL FOR HARMLESS ERROR AND, IF SO, WHAT HARMLESS ERROR TEST SHOULD THE APPELLATE COURT APPLY? We have jurisdiction. Art. V, § 3(b)(4), Fla. Const. The answer to

the certified question is yes. We find that the Second District was

correct to apply the harmless error standard. However, the proper

test is that set forth in State v. DiGuilio, 491 So. 2d 1129, 1135 (Fla.

1986). And applying that test here, we find that harmful error

occurred, so we quash the decision of the Second District to the

extent that it concludes otherwise, and remand for further

proceedings consistent with this decision.

I

On April 24, 2012, Joshua Davis shot three coworkers who

were visiting his home, killing two and severely wounding the third.

At his trial, the State introduced no evidence regarding a motive for

the shootings. Rather, “[t]he State’s theory was that Mr. Davis

intentionally shot the three men while under the influence of

marijuana,” which he had smoked with two of them. Davis, 311 So.

3d at 931-32. “[A]ccording to one of the State’s experts, [Davis was]

in a state of psychosis from having used the drug.” Id. Davis’s

seven-year-old daughter was at home and witnessed the shootings.

A grand jury indicted Davis on two counts of first-degree murder,

-2- one count of attempted first-degree murder, and one count of child

abuse on May 10, 2012.

The case was originally scheduled for trial in May 2015 before

Judge Donald Jacobsen, who in the intervening years ruled on

several pretrial matters. The trial was continued and, eventually,

Judge Jacobsen announced that he expected to leave the capital

felony division. His replacement would be Judge Jalal Harb.

Davis moved for Judge Jacobsen to remain on the case

because, aside from Judge Jacobsen’s knowledge of the facts and

his having ruled on many pretrial motions, Judge Harb had been a

prosecutor in the homicide division of the state attorney’s office

from August 2012 to March 2014, while Davis’s case was pending.

The State opposed and moved to strike Davis’s motion, arguing that

Judge Harb had no involvement in the prosecution of Davis’s case,

and that his having worked in the same division did not, without

more, support the inference that he was biased.

Judge Jacobsen presided at a hearing on these matters.

Judge Harb attended as an observer. The prosecutor argued that

Judge Harb could easily come up to speed on the case and

-3- explained the following about Judge Harb’s work at the state

attorney’s office:

Judge, I would like to put on the record that I did, when I received the defense motion, pull this file, as well as any homicide committee notes that took place while Judge Harb was in our division. I pulled this file and every attorney note that’s in this case. Judge Harb’s not touched this file. He never attended a homicide committee meeting regarding this case. Other than the fact that this was pending in the division when he was an attorney in that division, he’s had no contact with this file.

Davis, 311 So. 3d at 931. Judge Jacobsen denied Davis’s motion

but clarified that this did not prejudice Davis’s right to file a motion

to disqualify Judge Harb.

And indeed, when Judge Harb took over the capital felony

division in July 2015, Davis moved to disqualify him under section

38.10 of the Florida Statutes and Florida Rule of Judicial

Administration 2.330(e)(1). In his supporting affidavit, Davis listed

four reasons he feared he would not receive a fair trial:

(1) Judge Harb was an assistant state attorney in the homicide division while this case was pending and worked alongside the prosecutor in that division handling his case,

(2) [T]he homicide division functioned as a single unit with decisions being made not by individual prosecutors but rather by committee as a unified division, -4- (3) [T]he State’s argument in opposition to his motion for Judge Jacobsen to remain on the case was both strenuous and based on factual research about Judge Harb that the judge could not consider in ruling on a motion to disqualify, and

(4) Judge Harb was present at the hearing on the motion for Judge Jacobsen to remain on the case.

Davis, 311 So. 3d at 931. Judge Harb denied the motion as legally

insufficient. Davis did not file a petition for a writ of prohibition

seeking relief from that decision.

The case was tried in October 2016. The State’s theory was

that Davis’s use of marijuana left him in a state of psychosis, but

that he nonetheless intentionally shot the three victims. Davis did

not deny that he smoked marijuana, nor did he contest that he shot

the three men in the presence of his daughter. Instead, Davis

argued that the shootings were justified, as his friends were acting

strangely after reentering his house. Davis also presented an

alternative defense of insanity based on expert testimony that he

suffered from mental infirmity, which manifested itself in paranoid

beliefs and behavior. The State countered this theory with expert

testimony on drug-related paranoia.

-5- The jury found Davis guilty of two counts of the lesser

included offense of second-degree murder—one for each of the two

victims who were killed—guilty of attempted first-degree murder

with respect to the victim who survived, and guilty of child abuse.

Davis moved for a new trial, arguing, among other things, that

Judge Harb “showed bias in his rulings toward” the State. Davis

also identified a specific ruling of Judge Jacobsen’s that Judge Harb

reversed: Davis initially sought to conduct individual voir dire with

jury panelists about the defense of insanity; whereas Judge

Jacobsen had granted this request in a pretrial ruling, Judge Harb

ruled that such inquiry would be allowed only if an individual juror

asked to speak privately about the matter. Judge Harb denied the

motion for a new trial. The court sentenced Davis to three

concurrent life sentences for the murder counts, each with a

twenty-five-year minimum mandatory sentence based on the use of

a firearm, and a concurrent five-year sentence for child abuse.

On appeal, Davis challenged each of his three convictions,

arguing primarily that “his judgment and sentences should be

reversed and the case remanded for a new trial because Judge Harb

wrongly denied his motion for disqualification.” Davis, 311 So. 3d -6- at 932. Davis “abandoned any appellate issue concerning the

denial of the motion for new trial in which the allegation of actual

bias was made.” Id. The question before the Second District was

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