Hurst v. Florida, 577 U.S. 92

Florida jury convicted Hurst of murdering Cynthia Harrison; a separate sentencing proceeding sought death at the judge's sole discretion.
Under Florida law, the jury provides an advisory death or life recommendation, but the judge makes the ultimate sentencing findings and must write the order.
The Florida Supreme Court later vacated the death sentence; at resentencing the judge again relied on independent findings and the jury's advisory verdict.
The Court held Ring v. Arizona controls: a judge cannot impose death without jury-finding of aggravating factors that expose the defendant to greater punishment.
The majority overruled Spaziano and Hildwin to hold Florida's scheme unconstitutional; the case is remanded for further proceedings consistent with this ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Florida's capital sentencing scheme violates the Sixth Amendment	Hurst argues Ring requires jury findings for death-eligibility findings.	Florida contends jury findings are advisory and the judge's independent findings suffice.	Yes; scheme unconstitutional; jury must find aggravating factors.
Does the Florida jury recommendation fulfill Ring's requirement	Jury finding of aggravators is sufficient for death under Ring.	Advisory verdict plus judicial findings are constitutionally permissible.	No; Ring requires jury findings for aggravating circumstances.
Should prior precedents upholding Florida's scheme be overruled	Precedents should control; Ring consistency supports Florida scheme.	Stare decisis should be preserved to avoid overturning substantial law.	Overruled; Spaziano and Hildwin overruled to the extent inconsistent with Apprendi/Ring.

Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (jury must find aggravating factors to impose death)
Walton v. Arizona, 497 U.S. 639 (U.S. 1990) (pre-Apprendi view on jury findings)
Spaziano v. Florida, 468 U.S. 447 (U.S. 1984) ( Sixth Amendment jury findings not required for death in Florida)
Hildwin v. Florida, 490 U.S. 638 (U.S. 1989) (Sixth Amendment findings for death not required to be by jury)
Aplle v. United States, 133 S. Ct. 2151 (Supreme Court 2013) (Apprendi line of cases on elements and punishment)