Hurst v. Florida

136 S.Ct. 616 (2016)

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Nature of the Case

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Facts

Cynthia Harrison’s body was discovered in the freezer of the restaurant where she worked - bound, gagged, and stabbed over 60 times. The restaurant safe was unlocked and open, missing hundreds of dollars. A Florida jury convicted D of murdering his co-worker, Cynthia Harrison. A penalty-phase jury recommended that D’s judge impose a death sentence. Florida law required the judge to hold a separate hearing and determine whether sufficient aggravating circumstances existed to justify imposing the death penalty. The judge so found and sentenced D to death. The additional sentencing proceeding Florida employs is a “hybrid” proceeding “in which a jury renders an advisory verdict, but the judge makes the ultimate sentencing determinations.” The Florida Supreme Court vacated D’s sentence for reasons not relevant to this case. At resentencing, the sentencing judge conducted a new hearing during which D offered mitigating evidence that he was not a “major participant” in the murder because he was at home when it happened. The sentencing judge instructed the advisory jury that it could recommend a death sentence if it found at least one aggravating circumstance beyond a reasonable doubt: that the murder was especially “heinous, atrocious, or cruel” or that it occurred while d was committing a robbery. The jury recommended death by a vote of 7 to 5. The sentencing judge then sentenced d to death. The judge based the sentence in part on her independent determination that both the heinous-murder and robbery aggravators existed. She assigned “great weight” to her findings as well as to the jury’s recommendation of death. The Florida Supreme Court affirmed. The court rejected D’s argument that his sentence violated the Sixth Amendment in light of Ring where it was recognized “that capital defendants are entitled to a jury determination of any fact on which the legislature conditions an increase in the maximum punishment.” The Supreme Court granted certiorari to resolve whether Florida’s capital sentencing scheme violates the Sixth Amendment in light of Ring.