Robinson v. State, 260 So. 3d 1011

In 1995 Michael Lee Robinson pleaded guilty to first-degree murder, waived a penalty-phase jury, and asked the court to impose death; the trial court relied on his confession and proffered mitigation and sentenced him to death.
On direct appeal (Robinson I) the Florida Supreme Court vacated the death sentence and remanded for a new judge-only penalty phase, instructing the court to consider all mitigation in the record.
At the second penalty hearing the defense presented extensive mitigation; the court again found three aggravators, several mitigators, and reimposed death; Robinson’s direct appeal (Robinson II) and subsequent certiorari were denied, and the conviction became final in 2000.
Robinson pursued postconviction relief (Robinson III), alleging ineffective assistance for counsel’s handling of the jury-waiver issue; the Florida Supreme Court rejected the claim as procedurally barred and meritless because counsel followed the Court’s remand directive.
In 2017 Robinson filed a successive 3.851 motion invoking Hurst v. Florida and Hurst v. State (challenging his jury-waiver, Sixth and Eighth Amendment issues, and prior ineffective-assistance rulings); the postconviction court summarily denied relief and the Florida Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hurst decisions apply retroactively to Robinson whose sentence was final before Ring	Robinson: Hurst and Hurst v. State create new law that should apply and vacate his death sentence	State: Robinson’s sentence was final before Ring; Florida precedent bars retroactive Hurst relief	Held: No retroactive application; Hurst does not apply to Robinson
Whether Robinson can challenge his waiver of a penalty-phase jury under Hurst	Robinson: His waiver should be reexamined in light of Hurst	State: Claim is procedurally barred and previously adjudicated on the merits	Held: Claim is procedurally barred and merits already rejected; Mullens controls
Whether subsequent change in law (Hurst) invalidates an otherwise valid jury-waiver	Robinson: Hurst undermines prior waiver-related rulings	State: A valid, knowing waiver remains valid despite later change in law	Held: A valid waiver remains effective; subsequent law change does not undo it
Whether prior ineffective-assistance claims must be reconsidered because of Hurst	Robinson: Hurst affects disposition of earlier IAC claims	State: Prior IAC rulings were decided consistent with remand and are barred	Held: No relief; prior ineffective-assistance claims remain denied

Robinson v. State, 684 So.2d 175 (Fla. 1996) (vacating death sentence and remanding for judge-only penalty phase)
Robinson v. State, 913 So.2d 514 (Fla. 2005) (postconviction decision rejecting IAC claim about jury-waiver and denying relief)
Mullens v. State, 197 So.3d 16 (Fla. 2016) (Hurst does not invalidate a knowing, voluntary waiver of jury sentencing)
Asay v. State, 210 So.3d 1 (Fla. 2016) (Hurst not applied retroactively to sentences final before Ring)
Hurst v. State, 202 So.3d 40 (Fla. 2016) (Florida decision construing Hurst v. Florida)
Ring v. Arizona, 536 U.S. 584 (2002) (Sixth Amendment jury-trial principle applied to death-penalty factfinding)
Hitchcock v. State, 226 So.3d 216 (Fla. 2017) (reaffirming limits on Hurst retroactivity and application)