Today, the Supreme Court of the United States released its opinion in Hurst v. Florida.
What has happened here is that the highest court in the nation has ruled Florida’s process in death penalty trials violates the Sixth Amendment of the U.S. Constitution.
The Sixth Amendment provides: “In all criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury. . . .”
How does the Florida death penalty trial process violate the Sixth Amendment according to SCOTUS?
Under Florida law, jurors in a capital case make recommendations to the judge regarding whether or not a defendant should be sentenced to death or not. However, under that law, it was the Florida judge who presided over the capital case who made the final decision on whether or not the defendant was sentenced to die for the crime he or she had just been convicted.
All of the justices agreed that this procedure was in violation of the Sixth Amendment except one: Justice Samuel Alito dissented.
Specifically, SCOTUS holds that Florida’s process does not conform with its 2002 decision in Ring v. Arizona.
Florida Law Held to Violate Ring v. Arizona
In that case, Ring held that anyone facing the death penalty had a right to have a jury of their peers decide if the aggravating circumstances presented by the prosecution made them eligible for the death penalty.
Since the Florida process has juries advising the judge, but the trial judge making that ultimate decision, the High Court ruled that Florida’s process was unconstitutional.
The analysis the Ring Court applied to Arizona’s sentencing scheme applies equally to Florida’s. Like Arizona at the time of Ring, Florida does not require the jury to make the critical findings necessary to impose the death penalty. Rather, Florida requires a judge to find these facts. Fla. Stat. §921.141(3).
Although Florida incorporates an advisory jury verdict that Arizona lacked, we have previously made clear that this distinction is immaterial: “It is true that in Florida the jury recommends a sentence, but it does not make specific factual findings with regard to the existence of mitigating or aggravating circumstances and its recommendation is not binding on the trial judge.
A Florida trial court no more has the assistance of a jury’s findings of fact with respect to sentencing issues than does a trial judge in Arizona.” Walton v. Arizona, 497 U. S. 639, 648 (1990); accord, State v. Steele, 921 So. 2d 538, 546 (Fla. 2005) (“[T]he trial court alone must make detailed findings about the existence and weight of aggravating circumstances; it has no jury findings on which to rely”).
The Sixth Amendment protects a defendant’s right to an impartial jury. This right required Florida to base Timothy Hurst’s death sentence on a jury’s verdict, not a judge’s factfinding.
Florida’s sentencing scheme, which required the judge alone to find the existence of an aggravating circumstance, is therefore unconstitutional.
The judgment of the Florida Supreme Court is reversed, and the case is remanded for further proceedings not inconsistent with this opinion.
Update: Lenamon in Miami Herald on Hurst