Hurst v. Florida

PETITIONER: Timothy Lee Hurst
RESPONDENT: Florida
LOCATION: Popeye’s Restaurant

DOCKET NO.: 14-7505
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: Florida Supreme Court

CITATION: 577 US (2016)
GRANTED: Mar 09, 2015
ARGUED: Oct 13, 2015
DECIDED: Jan 12, 2016

ADVOCATES:
Seth P. Waxman - for the petitioner
Allen Winsor - Solicitor General of Florida, for the respondent

Facts of the case

Timothy Lee Hurst was charged and convicted of first-degree murder for killing his co-worker, Cynthia Harrison, during a robbery of the Popeye’s restaurant where they both worked. He was sentenced to death and appealed. On appeal, Hurst was granted a new sentencing trial because the Supreme Court of Florida found that his counsel should have investigated and presented evidence of Hurst’s borderline intelligence and possible organic brain damage. At his new sentencing trial, Hurst was prevented from presenting mental retardation evidence as an absolute bar to the imposition of the death penalty, though he was allowed to present it as mitigating evidence. The jury again sentenced Hurst to the death penalty by a vote of seven to five, and the Supreme Court of Florida affirmed.

In 2002, the Supreme Court decided the case Ring v. Arizona, in which the Court held that the Sixth Amendment required that the presence of aggravating factors, which Arizona’s death penalty sentencing scheme viewed as essentially elements of a larger offense, be determined by the jury. The Supreme Court of Florida had previously held that the decision in Ring v. Arizona did not apply to Florida’s death penalty sentencing scheme generally and specifically did not require that a jury’s recommendation of the death penalty be unanimous or that a jury determine the factual issue of a defendant’s potential mental retardation.

Question

In light of the Supreme Court’s decision in Ring v. Arizona, does the Florida death sentencing scheme, which does not require a jury to determine whether a capital defendant is mentally retarded or to unanimously sentence a defendant to death, violate the Sixth Amendment’s jury trial guarantee or the Eighth Amendment’s prohibition against cruel and unusual punishment?

Media for Hurst v. Florida

Audio Transcription for Oral Argument - October 13, 2015 in Hurst v. Florida

Audio Transcription for Opinion Announcement - January 12, 2016 in Hurst v. Florida

John G. Roberts, Jr.:

Justice Sotomayor has the opinion of the Court this morning in case 14-7505, Hurst versus Florida.

Sonia Sotomayor:

This case comes to us from the Supreme Court of Florida.

A Florida jury convicted petitioner Timothy Hurst of murder.

A second jury recommended that the judge in Hurst's case sentence Hurst to death.

Before Hurst was eligible for this sentence, however, Florida law required the judge to hold a separate hearing and determine for himself whether sufficient aggravating facts existed to justify the death sentence.

The judge followed this procedure and sentenced Hurst to die because she believed his crime was especially cruel and that it occurred during a robbery.

We reverse.

Hurst's death sentence violates the Sixth Amendment right to a jury trial.

This right requires a jury, not just the judge, to find any fact beyond a reasonable doubt if it exposes a defendant to additional punishment.

In Hurst's case, the maximum punishment he could have received on the basis of the first jury's verdict and second jury's recommendation was life imprisonment.

Florida law unconstitutionally allowed a judge to enhance Hurst's sentence by finding the critical facts missing from the jury verdicts.

This is not the first time we have reversed a capital case on this ground.

In Ring versus Arizona, a decision from 2002, we reversed an Arizona death sentence on the ground that a judge found the facts necessary to impose the death penalty.

Florida argues that this case is different because a jury recommended that Hurst receive a death sentence, but Florida fails to appreciate the central role its law gives a judge.

Under Florida law, the jury's function is strictly advisory only the judge's findings are necessary to impose the death penalty.

The state cannot now treat this advisory recommendation as the necessary fact finding required by the Sixth Amendment.

Reaching this conclusion requires us to confront two cases from the 1980s, Hildwin versus Florida and Spaziano versus Florida in which we upheld Florida's capital sentencing scheme.

In the years since those decisions, a line of over a dozen cases has undermined their reasoning.

We have since recognized that the Sixth Amendment often requires jury fact-finding even after a guilty verdict.

A point we did not appreciate in Hildwin or Spaziano.

Those decisions are overruled. Justice Breyer has filed an opinion concurring in the judgment.

Justice Alito has filed a dissenting opinion.