Hurst v. Florida
136 S. Ct. 616
| SCOTUS | 2016Background
- Hurst was convicted of first‑degree murder and sentenced to death after a separate Florida sentencing proceeding.
- Florida’s scheme requires a judge to make independent aggravating/mitigating findings after an advisory jury verdict before death can be imposed.
- At resentencing (2012) the jury recommended death 7–5 and the judge again found aggravators, issuing a death sentence.
- Florida Supreme Court affirmed, rejecting Hurst’s Sixth Amendment challenge in light of Ring.
- The Court overruled Spaziano and Hildwin to the extent they permitted judge‑made aggravator findings without a jury, and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Florida’s capital sentencing scheme violate the Sixth Amendment as Ring requires?</Issue, | Hurst | Florida | Yes; scheme unconstitutional |
| Can Florida rely on Blakely/precedent or stare decisis to justify the scheme?</Issue, | Hurst | Florida | Precedent overruled; scheme invalidated |
| Should Spaziano/Hildwin be preserved or overruled?</Issue, | Hurst (overrule) | Florida argues for preservation | Overruled to the extent they allow judge‑found aggravators without a jury |
| Is any potential error harmless?</Issue, | Hurst | Florida | Not reached; court does not apply harmless-error analysis here |
Key Cases Cited
- Ring v. Arizona, 536 U. S. 584 (2002) (held judge findings of aggravators violate Apprendi in capital cases)
- Walton v. Arizona, 497 U. S. 639 (1990) (jury findings not required for all sentencing issues in Florida’s system)
- Apprendi v. New Jersey, 530 U. S. 466 (2000) (any fact exposing defendant to greater punishment than jury verdict is an element)
- Blakely v. Washington, 542 U. S. 296 (2004) (facts admitted or established by plea do not justify broader sentencing without jury)
- Spaziano v. Florida, 468 U. S. 447 (1984) (Sixth Amendment not required to have jury findings for death‑eligibility facts (overruled))
- Hildwin v. Florida, 490 U. S. 638 (1989) (Sixth Amendment not require jury findings for death‑sentence factors (overruled))
- Tedder v. State, 322 So. 2d 908 (Fla. 1975) (trial court must weigh aggravating/mitigating factors with jury recommendation)