Hurst v. Florida

Hurst v. Florida

Argued October 13, 2015
Decided January 12, 2016
Full case name Timothy Lee Hurst, Petitioner v. Florida
Docket nos. 14–7505
Citations

577 U.S. ___ (more)

Opinion Announcement Opinion announcement
Holding
Florida's capital sentencing scheme violates the Sixth Amendment in light of Ring v. Arizona.
Court membership
Chief Justice
John G. Roberts
Case opinions
Majority Sotomayor, joined by Roberts, Scalia, Kennedy, Thomas, Ginsburg, Kagan
Concurrence Breyer
Dissent Alito
Laws applied
U.S. Const. amend. VI

Hurst v. Florida, 577 U.S. ___ (2016), was a United States Supreme Court case in which the Court applied the rule of Ring v. Arizona, 536 U.S. 584 (2002), to the Florida capital sentencing scheme, holding that the Sixth Amendment requires a jury to find the aggravating factors necessary for imposing the death penalty. In Florida the jury made recommendations but the judge decided the facts.

Background

Timothy Hurst was charged with killing Cynthia Harrison, a co-worker at Popeye's Chicken. The 1998 murder was part of a botched robbery at the Escambia County restaurant. Under Florida law, the maximum sentence a capital felon may receive on the basis of a conviction alone is life imprisonment. He may be sentenced to death, but only if an additional sentencing proceeding “results in findings by the court that such person shall be punished by death.” Fla. Stat. §775.082(1). In that proceeding, the sentencing judge first conducts an evidentiary hearing before a jury. §921.141(1). Next, the jury, by majority vote, renders an “advisory sentence.” §921.141(2). Notwithstanding that recommendation, the court must independently find and weigh the aggravating and mitigating circumstances before entering a sentence of life or death. §921.141(3).

A Florida jury convicted petitioner Hurst of first-degree murder for The jury recommended the death penalty and the court sentenced Hurst to death, but he was granted a new sentencing hearing on appeal. At resentencing, the jury again recommended death, and the judge again found the facts necessary to sentence Hurst to death. The Florida Supreme Court affirmed, rejecting Hurst’s argument that his sentence violated the Sixth Amendment in light of Ring v. Arizona, 536 U. S. 584. This Court found unconstitutional an Arizona capital sentencing scheme that permitted a judge rather than the jury to find the facts necessary to sentence a defendant to death.

Opinion of the Court

Justice Sonia Sotomayor wrote the majority opinion of the Court, ruling that Florida's capital sentencing scheme, requiring that a judge instead of a jury make the critical findings necessary to impose the death penalty, violates the Sixth Amendment in light of Ring v. Arizona. The Court also rejected Florida's counterarguments. First, Florida argued that the jury’s recommendation necessarily included an aggravating circumstance finding, but it still violates Ring because the jury's function is still advisory only. Second, Florida's reliance on Blakely v. Washington is misplaced: Florida alleges that Hurst's counsel allegedly admitted the existence of a robbery, but Blakely applied Apprendi to facts admitted in a guilty plea, in which the defendant necessarily waived his right to a jury trial, while Florida has not explained how Hurst’s alleged admissions accomplished a similar waiver. In any event, Hurst never admitted to either aggravating circumstance alleged. Third, although the Court has repeatedly upheld Florida's capital sentencing scheme in the past (such as Hildwin v. Florida and Spaziano v. Florida), it does not mean that stare decisis compels the Court to do so in this case. Instead, time and subsequent cases have "washed away" the logic of Spaziano and Hildwin. And finally the Court normally leaves it to state courts to consider whether an error is harmless.

Justice Stephen Breyer wrote a concurring opinion, stating that he cannot join the majority's opinion because of the reasons he explained in his concurring opinion in Ring (i.e., since he did not fully agree with the majority opinion in Ring, he could not support the majority's rationale here in Hurst). However, he agreed with striking Florida's scheme, referring back to his concurring opinion in Spaziano, among others, that he believes that any imposition of the death penalty by a single government official instead of a jury violates the Eighth Amendment.

Justice Samuel Alito dissented, disagreeing with the majority on basically overruling Hildwin and Spaziano. Instead, he would have preferred that the Court reconsider Ring directly. He also wrote that Arizona's sentencing scheme is much different than Florida's because under the former a jury plays no role in the process. But in Florida, "the jury plays a critically important role. Our decision in Ring did not decide whether this procedure violates the Sixth Amendment, and I would not extend Ring to cover the Florida system."

Effects

Florida has about 400 inmates on death row, the most of any state except California. It is not clear how many might receive new resentencing hearings as a result of this decision. As of late January 2016, about 40 inmates have appeals pending.[1] The Florida legislature needs to revise its death penalty law to address the Court's concerns about ensuring that the jury determines what aggravating facts are to be considered in a capital case for which the death penalty might be chosen.[2]

See also

References

  1. ↑ LIZETTE ALVAREZ, "Supreme Court Ruling Has Florida Scrambling to Fix Death Penalty Law", New York Times, 2 February 2016, accessed 3 February 2016
  2. ↑ ADAM LIPTAK, "Supreme Court Strikes Down Part of Florida Death Penalty", New York Times, 12 January 2016, accessed 3 February 2016
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