Cary Michael Lambrix v. State of Florida
227 So. 3d 112
| Fla. | 2017Background
- Lambrix was sentenced to death in 1986 for two 1983 murders; the jury recommended death by nonunanimous votes (10–2 and 8–4).
- In 2017, while an eighth successive postconviction motion was pending, the Governor set an execution date; the circuit court denied Lambrix’s motion and rehearing, and the appeal was expedited.
- Lambrix sought relief based on Hurst-related decisions and on Florida’s 2017 statute requiring unanimous jury recommendations for death.
- He argued (1) his death sentences are unconstitutional under chapter 2017-1 (unanimity requirement), (2) prior newly discovered-evidence claims should be reconsidered in light of Hurst, (3) Eighth Amendment violation, and (4) equal protection violations from this Court’s retroactivity rulings.
- The Florida Supreme Court treated the filing as successive and, relying on its precedent (Asay, Hitchcock, Asay VI, and its prior Lambrix decision), affirmed denial of relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hurst and related Florida decisions entitle Lambrix to relief despite his sentences being final in 1986 | Lambrix: Hurst and Florida cases (Hurst v. State, Perry) mean his nonunanimous jury recommendations violate the Constitution and require relief | State: Lambrix’s convictions and sentences were final; this Court’s retroactivity and precedent (Asay V/VI, Hitchcock, Mosley) preclude relief | Denied — Court affirmed denial under its controlling precedent; Lambrix not entitled to Hurst-based relief |
| Whether Florida’s 2017 unanimity statute (chapter 2017-1) creates a substantive retroactive right to vacate prior nonunanimous death sentences | Lambrix: Chapter 2017-1’s unanimity requirement supports relief for nonunanimous preexisting death sentences | State: The statute is prospective and does not entitle defendants with final sentences to relief | Denied — Court rejected claim; statute did not provide retroactive relief |
| Whether Hurst creates an Eighth Amendment unreliability ground entitling Lambrix to relief | Lambrix: Nonunanimous death recommendations render sentences unreliable under the Eighth Amendment | State: Court’s prior retroactivity and Sixth Amendment-focused holdings control; no Eighth-based retroactive relief | Denied — Court declined to grant Eighth Amendment-based retroactivity relief |
| Whether the Court’s retroactivity rulings violate equal protection or due process | Lambrix: Denying relief to him while granting it to similarly situated defendants is arbitrary and violates due process/equal protection | State: Application of settled retroactivity doctrine and precedent is consistent and not arbitrary | Denied — Court upheld consistency of its precedent; rejected equal protection/due process challenge |
Key Cases Cited
- Hurst v. State, 202 So.3d 40 (Fla. 2016) (addressing Hurst error under Florida law)
- Perry v. State, 210 So.3d 630 (Fla. 2016) (Hurst-related sentencing analysis)
- Lambrix v. State, 217 So.3d 977 (Fla. 2017) (prior Lambrix opinion denying Hurst relief)
- Asay v. State, 210 So.3d 1 (Fla. 2016) (Asay V; retroactivity and Hurst analysis)
- Asay v. State, 224 So.3d 695 (Fla. 2017) (Asay VI; reaffirming precedent on Hurst retroactivity)
- Hitchcock v. State, 226 So.3d 216 (Fla. 2017) (addressing Hurst claims and retroactivity)
- Mosley v. State, 209 So.3d 1248 (Fla. 2016) (retroactivity discussion related to Hurst)
- Ring v. Arizona, 536 U.S. 584 (2002) (Sixth Amendment jury-trial principle informing Hurst)
- Gaskin v. State, 218 So.3d 399 (Fla. 2017) (related Hurst-era retroactivity/dissenting analyses)