312 So.3d 59
Fla.2021Background
- In 1983 Joel Dale Wright was convicted of first-degree murder (capital), sexual battery, burglary of a dwelling, and grand theft, and was sentenced to death.
- Wright’s direct review and early postconviction challenges were denied; his death sentence became final in January 1986 when the U.S. Supreme Court denied certiorari.
- Wright filed a third successive postconviction motion in 2017 asserting Hurst-related claims and reliance on chapter 2017-1, Laws of Florida to attack his death sentence.
- He argued Hurst v. State created a new substantive offense (“capital first-degree murder”) and that the jury determinations described in Hurst are elements that must have been found by a jury at trial.
- The trial court denied relief; Wright appealed. The Florida Supreme Court affirmed, holding Hurst did not create a new offense, did not change the elements of first-degree murder, and that Hurst and chapter 2017-1 do not apply retroactively to pre-Ring final defendants.
- The Court declined to resolve issues based on State v. Poole because Wright’s claims failed even under pre-Poole precedent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hurst created a new substantive offense ("capital first-degree murder") and made Hurst jury determinations elements of the crime | Wright: Hurst created a new offense and Hurst jury findings are elements that must be found by a jury, so his death sentence must be vacated | State: Hurst did not change the elements; first-degree murder has always been capital; Hurst’s jury findings are sentencing determinations, not elements | Denied. Court held Hurst did not create a new offense or change the elements of first-degree murder; Wright’s argument rejected (citing Foster) |
| Whether Hurst and chapter 2017-1 apply retroactively to defendants whose sentences were final before Ring | Wright: Seeks retroactive application to vacate his death sentence | State: Asay and subsequent Florida precedent deny retroactive application to pre-Ring final defendants | Denied. Court applied Asay/Hitchcock line and refused retroactive relief |
| Whether legislative enactment (chapter 2017-1) created a substantive right requiring vacatur | Wright: Chapter 2017-1 created substantive rights that should apply to his case | State: Chapter 2017-1 enacted jury sentencing procedure but did not change substantive elements | Denied. Court treated chapter 2017-1 as procedural and not a basis for retroactive vacatur |
| Whether State v. Poole requires a different result | Wright: Criticizes Poole and invokes it for relief | State: Relief unnecessary because Wright’s claims fail under pre-Poole law | Not addressed on merits. Court affirmed denial without resolving Poole-based arguments |
Key Cases Cited
- Hurst v. Florida, 577 U.S. 92 (2016) (U.S. Supreme Court decision invalidating Florida’s prior sentencing scheme)
- Hurst v. State, 202 So. 3d 40 (Fla. 2016) (Florida Supreme Court interpretation requiring jury findings for death sentences)
- Ring v. Arizona, 536 U.S. 584 (2002) (jury must find facts authorizing death penalty)
- Foster v. State, 258 So. 3d 1248 (Fla. 2018) (rejected claim that Hurst created a new offense; Hurst did not change murder elements)
- Asay v. State, 210 So. 3d 1 (Fla. 2016) (denied retroactive application of Hurst to defendants whose sentences were final at Ring)
- Hitchcock v. State, 226 So. 3d 216 (Fla. 2017) (applied Asay to deny retroactivity of Hurst)
- Poole v. State, 297 So. 3d 487 (Fla. 2020) (partially receded from Hurst; referenced by Wright but not dispositive here)