291 So.3d 900
Fla.2020Background
- Lucious Boyd is a death‑sentenced prisoner who filed a successive postconviction motion under Fla. R. Crim. P. 3.851 and alternatively a motion under rule 3.800(a) seeking relief based on Hurst-related decisions and implementing Florida legislation.
- The trial court summarily denied the motion; Boyd previously sought Hurst relief in a habeas petition that was denied.
- The asserted Hurst error concerned Florida procedures for imposing death and the need for jury findings required by Hurst v. Florida and this Court’s Hurst v. State decision.
- At trial the court found as an aggravator that the murder occurred during commission of kidnapping and sexual battery; the jury had returned guilty verdicts for the contemporaneous armed kidnapping and sexual battery.
- The Florida Supreme Court affirmed the summary denial, holding Boyd’s claims procedurally barred and, on the merits, foreclosed by the Court’s interpretation in State v. Poole and the U.S. Supreme Court’s decision in McKinney v. Arizona. Justice Labarga concurred only in the result.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Boyd's successive Hurst‑based 3.851/3.800(a) motion is procedurally barred | Boyd: Hurst decisions and subsequent legislation provide new law entitling relief | State: Claims are successive/previously litigated and thus procedurally barred | Court: Claims are procedurally barred |
| Whether Hurst error requires vacatur/new penalty proceedings | Boyd: Hurst/Hurst v. State require jury findings and mandate relief | State: No Hurst error because a unanimous jury finding of an aggravator exists | Court: On merits, relief foreclosed (Poole/McKinney); no Hurst entitlement |
| Whether an aggravating circumstance was found unanimously | Boyd: Florida sentencing process lacked required unanimous jury finding on aggravators | State: Jury guilty verdicts for kidnapping and sexual battery establish unanimity for that aggravator | Court: Aggravator (murder during kidnapping/sexual battery) established by unanimous verdicts |
| Whether implementing legislation changes outcome | Boyd: New legislative scheme supports Hurst‑based relief | State: Legislation and precedent do not mandate relief in this case | Court: Legislation does not alter result; relief denied |
Key Cases Cited
- Hurst v. Florida, 136 S. Ct. 616 (2016) (held jury must find facts making defendant death‑eligible)
- Hurst v. State, 202 So. 3d 40 (Fla. 2016) (Florida Supreme Court’s application of Hurst requiring jury findings/unanimity)
- McKinney v. Arizona, 140 S. Ct. 702 (2020) (jury must find aggravating circumstance making defendant death‑eligible; jury need not weigh or make ultimate sentencing decision)
- Boyd v. State, 910 So. 2d 167 (Fla. 2005) (trial court’s original findings including that murder occurred during kidnapping and sexual battery)