Term: 2015
Docket: 14-7505
Hurst v. Florida
- Pro
14-7505 HURST V. FLORIDA DECISION BELOW: 147 So.3d 435 LIMITED TO THE FOLLOWING QUESTION: WHETHER FLORIDA’S DEATH SENTENCING SCHEME VIOLATES THE SIXTH AMENDMENT OR THE EIGHT AMENDMENT IN LIGHT OF THIS COURT’S DECISION IN RING v. ARIZONA, 536 U.S. 584 (2002) CERT. GRANTED 3/9/2015 QUESTION PRESENTED: WHETHER THE FLORIDA SUPREME COURT CORRECTLY HELD THAT THE JURY IN A DEATH PENALTY CASE DOES NOT HAVE A CONSTITUTIONAL OBLIGATION TO RENDER A VERDICT IN THE PENALTY PHASE OF WHETHER THE DEFENDANT IS MENTALLY RETARDED OR NOT WHEN EVIDENCE HAS BEEN PRESENTED TO SUPPORT SUCH A CONCLUSION. WHETHER THE SUPREME COURT OF FLORIDA HAS CORRECTLY CONCLUDED THAT THIS COURT’S DECISION IN RING v. ARIZONA, 536 U.S. 584 (2002) (1) HAS NO APPLICABILITY TO FLORIDA'S DEATH SENTENCING SCHEME GENERALLY, (2)THAT SPECIFICALLY IT DOES NOT REQUIRE THE JURY'S RECOMMENDATION OF DEATH BE UNANIMOUS, (3) THAT THE JURY'S FINDINGS OF AGGRAVATING FACTORS NEED NOT BE UNANIMOUS, (4) THAT THE JURY HAS NO ROLE IN DETERMINING THE FACTUAL ISSUE OF THE DEFENDANT'S MENTAL RETARDATION, AND (5) THAT THE LACK OF UNANIMITY DOES NOT OFFEND OUR EVOLVING STANDARDS OF DECENCY AS REQUIRED BY THE EIGHTH AMENDMENT? LOWER COURT CASE NUMBER: SC12-1947
In the 2015 case Hurst v. Florida, the U.S. Supreme Court ruled that Florida's death penalty sentencing procedure was unconstitutional because it violated the Sixth Amendment's guarantee of a trial by jury. The case involved Timothy Lee Hurst, who had been sentenced to death for murder in Florida where judges rather than juries held the final say on whether certain aggravating factors justified a sentence of death or life imprisonment without parole. In an 8-1 decision, with Justice Samuel Alito dissenting, the court found that this process diminished jurors' role and increased judges' discretion beyond constitutional bounds as established in prior cases such as Ring v. Arizona (2002). This ruling invalidated Florida’s capital sentencing scheme and potentially impacted hundreds of inmates on death row in Florida.
In the dissenting opinion for Hurst v. Florida, Justice Alito argued that the majority's decision was not justified by either legal precedent or logic. He contended that the Court had misinterpreted its own previous rulings on capital sentencing and wrongly concluded that a jury must make specific factual findings about aggravating circumstances in order to impose a death sentence. According to Justice Alito, this requirement is not found in any of the Court’s prior decisions and contradicts traditional practice where judges often decide sentencing factors. Furthermore, he pointed out that even if such a requirement did exist, it would be satisfied under Florida law because juries are instructed to consider all relevant evidence before recommending a sentence. Finally, he criticized the majority for failing to respect state sovereignty and interfering with Florida's ability to design its own criminal justice system.
