William Kenneth Taylor v. State of Florida, 246 So. 3d 204

William Kenneth Taylor was convicted of first-degree murder, attempted first-degree murder, armed robbery, robbery with a firearm, and armed burglary; the jury recommended death unanimously (12–0).
Trial court found three statutory aggravators (felony probation, prior violent felony, pecuniary gain) and no statutory mitigators; it found multiple nonstatutory mitigators but ultimately sentenced Taylor to death.
Taylor’s convictions and death sentence were affirmed on direct appeal (Taylor I); he later filed and was denied an initial 3.851 postconviction motion and a habeas petition (Taylor II).
In 2017 Taylor filed a successive Rule 3.851 motion asserting Hurst and Caldwell claims; the postconviction court summarily denied relief.
The Florida Supreme Court reviewed purely legal issues de novo and affirmed the denial, holding any Hurst error harmless given the unanimous jury recommendation and finding the Caldwell claim procedurally barred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Taylor's death sentence violates the Sixth Amendment under Hurst	Taylor argued Hurst requires a jury finding of the facts necessary for death; his sentence is invalid under Hurst/Hurst v. Florida	State argued Taylor received a unanimous jury recommendation, which Florida courts treat as satisfying Hurst’s requirement	Court held any Hurst error was harmless beyond a reasonable doubt because of the unanimous 12–0 recommendation; Hurst relief denied
Whether the jury’s advisory instructions violate the Eighth Amendment under Caldwell	Taylor argued that repeatedly telling the jury its role was advisory undermined its responsibility and violated Caldwell	State relied on procedural bar and prior rejection of this claim on direct appeal	Court held claim is procedurally barred (raised and rejected on direct appeal)

Hurst v. Florida, 136 S. Ct. 616 (2016) (U.S. Supreme Court decision requiring jury findings for death-penalty factfinding)
Hurst v. State, 202 So. 3d 40 (Fla. 2016) (Florida Supreme Court interpretation of Hurst requiring jury role in death sentencing)
Davis v. State, 207 So. 3d 142 (Fla. 2016) (holding a unanimous jury recommendation satisfies Hurst’s requirements)
Caldwell v. Mississippi, 472 U.S. 320 (1985) (Eighth Amendment prohibits undermining jury’s sense of responsibility)
Taylor v. State, 937 So. 2d 590 (Fla. 2006) (direct-appeal opinion affirming conviction and death sentence)