Hurst V. Florida Case Study

Hurst v. Florida
577 US _ (2016)

2. The petitioner, Timothy Hurst, was convicted of first degree murder and the jury recommended the death penalty to the judge in Florida, who then sentenced Hurst to death. Hurst appealed to the Florida Supreme Court and was granted resentencing. The Florida Supreme Court rejected Hurst’s argument and reaffirmed his sentence. The Supreme Court of the United States granted certiorari.

3. Hurst had bound, gagged, and then stabbed his coworker over 60 times during a robbery at his place of employment. Her body was found in the freezer and the safe opened and missing hundreds of dollars. Witnesses came forth and testified that Hurst had planned to rob the store, and the night that it happened only Hurst and his now deceased coworker were the only two scheduled to work. The judge had instructed the jury that they could convict Hurst of
first degree murder under two theories being an unlawful killing during a robbery or a premeditated murder. The jury convicted Hurst of first degree murder but did not specify under which theory. The judge independently agreed and said that the crime was heinous and sentenced Hurst to death. Later at Hurst’s resentencing Hurst had said that he was not a major part of the crime because he was at home when his coworker was killed. The judge told the advising jury that they could make their recommendation of the death penalty if they could find one aggravating factor beyond reasonable doubt that the crime was heinous or if the murder occurred during the robbery. Again, the jury recommended death but without specifics, and the judge independently decided that the crime was especially atrocious and heinous enough for the death penalty. Florida state law says that the highest sentence a capital felon can receive with only conviction is life in prison with no chance of parole. Florida requires an additional hearing be held and that the court find aggravating factors necessary to sentence the felon to death. The jury is purely advisory and makes a recommendation, and then the judge makes the sentence. Hurst then argued that Florida’s sentencing process violated the 6th amendment. The Florida Supreme Court ignored Hurst’s claim and reaffirmed the previous sentence.

4. Did Florida violate the 6th amendment with their process to sentence capital punishment?

5. Yes, and the court reversed. The 6th amendment holds that a jury, not a judge must find the facts necessary to sentence an individual to death. In light of Ring v Arizona, the Supreme Court of the United States found Florida’s sentencing process unconstitutional.

6. Reasoning of the Court: Starting off with Florida’s sentencing scheme, the highest sentence a felon can receive in Florida is life imprisonment. (§775.082(1)). To impose the death penalty, an additional evidentiary hearing must be held in front of the judge and a jury. (Fla. Stat. §921.141(1) (2010)). The jury is only advisory and gives their recommendation to the court and the judge finds the aggravating factors necessary to sentence the felon to death. (Ring v. Arizona, 536 U. S. 584, 608, n. 6 (2002)). Hurst’s jury advised the death penalty, and the judge independently agreed. Hurst had a resentencing hearing where he attempted to offer mitigating evidence. The jury offered their recommendation again for the death penalty, and yet again ignored providing a specific theory or justification being an unlawful killing during a robbery or premeditated murder. The judge again documented that the jury’s recommendation held great weight and independently found that the crime was heinous and sentenced Hurst to death again. Florida’s Supreme Court affirmed the decision and shot down Hurst’s argument that Florida’s sentencing scheme violates the 6th amendment due to the repeated support of their sentencing scheme. (Hildwin v. Florida (1989)). The Supreme Court shot this down and reasoned that Apprendi v New Jersey applied in Ring v. Arizona, just as it applies to Hurst v Florida. The Apprendi rule says that any fact that would make the defendant have a worse punishment than already decided by a jury’s guilty verdict, must be resubmitted to another jury to decide, not a judge. It keeps judges from giving a heavier sentence from than what the jury could prove beyond a reasonable doubt. The Supreme Court holds that Florida’s “advisory” jury is immaterial. Florida tried to fight using stare decisis, and Hildwin v. Florida as a basis and another case, Spaziano v. Florida. The Supreme Court overruled both. The main reasoning of the court is that the 6th amendment protects a defendant’s right to an impartial jury, not a fact finding judge. And so it was reversed.

7. Justice Breyer was concurring in judgement but did not agree with the Court. Breyer noted that the 8th amendment requires a jury, not a judge sentence a defendant to death. It is the responsibility of a jury and not of a single government official.

Justice Alito wrote a dissenting opinion. He notes that the Supreme Court has acknowledged that they have review and upheld the decisions of the Florida court for a quarter of a century. Alito disagrees with reversing the Supreme Courts decision on Hildwin and Spaziano without reconsidering the cases and precedents in which those cases were ruled on. He also notes that Arizona and Florida’s sentencing schemes were very different whereas in Arizona a jury played no part and in Florida it did and he does not believe that extending Ring to cover Florida’s process as well was the correct thing to do. He states that he would’ve affirmed the Florida Supreme Court and said that it was a harmless error because the evidence suggests and shows that beyond unreasonable doubt the crime was especially cruel and heinous and the murder had occurred 17 years ago and needed justice.

8.
It is difficult to state my personal opinion of the Court because I understand where Justice Alito is coming from. Although I believe in due process and that even though someone is accused of committing a horrible crime, that they are still afforded their constitutional rights. The justice system is by far perfect. A lot of mistakes get made and a lot of people share the same view that they would rather lock up the innocent than let a guilty man run free. A part of me thinks that the court handled this case as professionally as possible, and that after Ring v. Arizona, Florida should’ve changed their statute to reflect and avoid this battle all together. Another part of me sees Florida’s argument that if their sentencing scheme had been reaffirmed and upheld for a quarter of a century even on similar cases, that it wouldn’t be over turned. In the end, as much as I do not like it, I think the court made the right decision. I wouldn’t necessarily say that justice was served, and now unfortunately because of this decision, a lot of Florida’s death penalty cases can be appealed and over
turned.