Michael Gordon Reynolds v. State of Florida, 251 So. 3d 811

Michael Reynolds was convicted of two counts of first-degree murder (Robin and Christina Razor), second-degree murder, and burglary; jury recommended death unanimously for both first‑degree murder counts.
At the penalty phase Reynolds knowingly and repeatedly waived presenting mitigation to the jury; trial counsel later presented mitigation at a Spencer hearing where the trial court found several mitigators but gave them little weight and imposed death sentences.
Reynolds’s convictions and death sentences were affirmed on direct appeal (Reynolds I) and his certiorari petition was denied by the U.S. Supreme Court in 2007.
After Hurst v. State and Hurst v. Florida (establishing jury unanimity and jury factfinding requirements for death sentences), Reynolds filed a successive 3.851 motion arguing (1) Sixth Amendment Hurst error and (2) an Eighth Amendment Caldwell-based claim that pre‑Hurst jury instructions misled jurors about their responsibility.
The circuit court denied relief; the Florida Supreme Court affirmed, holding the Hurst error harmless beyond a reasonable doubt and rejecting Hurst‑induced Caldwell claims to Standard Jury Instruction 7.11.

Issue	Reynolds' Argument	State's Argument	Held
Whether Hurst error (lack of unanimous jury factfinding) violated the Sixth Amendment and requires vacatur	Hurst requires unanimous jury findings on sufficiency/outweighing; Reynolds contends his sentences are invalid and not harmless because jury did not hear mitigation and he waived mitigation under the prior scheme	Hurst applies retroactively but any Hurst error is harmless beyond a reasonable doubt: unanimous jury recommendation, standard instructions given, and overwhelming aggravation outweighs minimal mitigation	Court: Hurst error was harmless beyond a reasonable doubt; affirmed death sentences (no relief)
Whether pre‑Hurst jury instructions violated the Eighth Amendment under Caldwell because they minimized jury responsibility	Reynolds: standard instruction (advisory jury, judge final) misled jurors after Hurst, undermining reliability and requiring relief under Caldwell	State: Romano and precedent foreclose retroactive Caldwell challenges to instructions that accurately described the law at the time; pre‑Hurst instructions did not mislead jurors under controlling law	Court: Hurst‑induced Caldwell claims against Standard Jury Instruction 7.11 fail; no Eighth Amendment violation and no relief

Reynolds v. State, 934 So.2d 1128 (Fla. 2006) (direct appeal describing convictions, waiver of mitigation, and penalty proceedings)
Hurst v. State, 202 So.3d 40 (Fla. 2016) (Florida decision requiring jury unanimity and jury factfinding for death sentences)
Ring v. Arizona, 536 U.S. 584 (2002) (Sixth Amendment jury‑factfinding rule for death penalties)
Caldwell v. Mississippi, 472 U.S. 320 (1985) (Eighth Amendment prohibits leading jurors to believe responsibility for death sentence rests elsewhere)
Romano v. Oklahoma, 512 U.S. 1 (1994) (Caldwell applies only where jury was affirmatively misled about its role)
DiGuilio v. State, 491 So.2d 1129 (Fla. 1986) (harmless‑error standard emphasizing effect on the trier of fact)
Kaczmar v. State, 228 So.3d 1 (Fla. 2017) (post‑Hurst harmless‑error analysis for unanimous jury recommendations)
Davis v. State, 207 So.3d 142 (Fla. 2016) (harmless‑error framework post‑Hurst; consideration of jury instructions and unanimity)