Truehill v. Florida, 138 S. Ct. 3

Petitioners Quentin Marcus Truehill and Terence Oliver are Florida capital defendants who raised Eighth Amendment challenges to their death sentences.
They argued Florida jury instructions impermissibly downplayed jurors’ responsibility by repeatedly describing the jury’s role as advisory.
The Florida Supreme Court previously rejected similar Caldwell challenges under a sentencing scheme where judges, not juries, were the final sentencer.
This Court’s decision in Hurst v. Florida undermined that scheme by holding that judges cannot be the sole finders of aggravating circumstances necessary for death sentences.
Because Hurst altered the underlying rationale, petitioners asked the Florida Supreme Court to reconsider the Caldwell-based Eighth Amendment claim; the state court did not address that issue.
The Supreme Court denied certiorari; Justices Sotomayor, Ginsburg, and Breyer dissented, arguing the unanswered, potentially meritorious Eighth Amendment claim warranted vacatur and remand given the stakes in capital cases.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Florida jury instructions violated the Eighth Amendment by diminishing juror responsibility (Caldwell challenge)	Instructions repeatedly labeled jury verdicts as merely advisory, reducing jurors’ sense of responsibility and violating Caldwell	Florida relied on prior state-court precedent rejecting Caldwell where judge was final sentencer; instructions were permissible under that framework	Certiorari denied; Supreme Court did not reach the merits. Dissenters would vacate and remand for state court consideration.

Caldwell v. Mississippi, 472 U.S. 320 (1985) (holding comments that minimize jury’s responsibility at capital sentencing violate the Eighth Amendment)
Beer v. United States, 564 U.S. 1050 (2011) (remand appropriate where lower court failed to address a raised claim)
Youngblood v. West Virginia, 547 U.S. 867 (2006) (per curiam) (remanding for consideration of an unaddressed constitutional claim)
Brady v. Maryland, 373 U.S. 83 (1963) (establishing prosecution’s obligation to disclose exculpatory evidence)