Hurst V. Florida

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Hurst v. Florida

Case Citation / Caption:

- Hurst v. Florida

- U.S. Supreme Court

- 577 US _ (2016)

- Jan 12, 2016

Parties:

The case was held between Timothy Lee Hurst and Florida. Timothy Lee Hurst was petitioner from Florida state while Florida was respondent in the case.

Procedural History:

Petitioner was sentenced to death after being charged for first-degree murder. However, he got a new sentence trial on appeal but again he was sentenced to death by a vote of seven to five. The court did not provide mental retardation evidence for its death recommendations which violated the sixth amendment. In 2002, Ring v. Arizona was decided in supreme court which held that sixth amendment is necessary that means the presence of aggravating factors for a death sentence while in this case, this scheme was not considered ADDIN ZOTERO_ITEM CSL_CITATION {"citationID":"iFK3TqYI","properties":{"formattedCitation":"(Cooke et al.)","plainCitation":"(Cooke et al.)","noteIndex":0},"citationItems":[{"id":1234,"uris":["http://zotero.org/users/local/mlRB1JqV/items/8555SWTN"],"uri":["http://zotero.org/users/local/mlRB1JqV/items/8555SWTN"],"itemData":{"id":1234,"type":"article-journal","title":"Revisiting the Decision of Death in Hurst v. Florida","container-title":"Journal of the American Academy of Psychiatry and the Law Online","page":"483-490","volume":"44","issue":"4","source":"jaapl.org","abstract":"The United States Supreme Court has considered the question of whether a judge or a jury must make the findings necessary to support imposition of the death penalty in several notable cases, including Spaziano v. Florida (1984), Hildwin v. Florida (1989), and Ring v. Arizona (2002). In 2016, the U.S. Supreme Court revisited the subject in Hurst v. Florida. Florida Statute § 921.141 allows the judge, after weighing aggravating and mitigating circumstances, to enter a sentence of life imprisonment or death. Before Hurst, Florida's bifurcated sentencing proceedings included an advisory sentence from jurors and a separate judicial hearing without juror involvement. In Hurst, the Court revisited the question of whether Florida's capital sentencing scheme violates the Sixth Amendment, which requires a jury, not a judge, to find each fact necessary to impose a sentence of death in light of Ring. In an eight-to-one decision, the Court reversed the judgment of the Florida Supreme Court, holding that the Sixth Amendment requires a jury to find the aggravating factors necessary for imposing the death penalty. The role of Florida juries in capital sentencing proceedings was thereby elevated from advisory to determinative. We examine the Court's decision and offer commentary regarding this shift from judge to jury in the final imposition of the death penalty and the overall effect of this landmark case.","ISSN":"1093-6793","note":"PMID: 28003393","language":"en","author":[{"family":"Cooke","given":"Brian K."},{"family":"Ginory","given":"Almari"},{"family":"Zedalis","given":"Jennifer"}],"issued":{"date-parts":[["2016",12,1]]}}}],"schema":"https://github.com/citation-style-language/schema/raw/master/csl-citation.json"} (Cooke et al.).

Statement of Facts:

Jury prevented Hurst to present his mental retardation evidence and only allowed to present mitigating evidence. If the presence of aggravating factors were important in the previous case then why the jury ignored it in this case. The jury gave recommendations on the factual issue for mental retardation evidence of petitioner.

Issue(s):

Based on Ring v. Arizona decision, does Florida violated the sixth amendment about jury trial guarantee by not considering the mental health of the defender?

Holding(s):

Florida violated the sixth amendment in the light of Ring v. Arizona court decision. It means that judge has to collect necessary fact to sentence death.

Reasoning:

On January 12, 2016 justice Sotomayor delivered for the majority 8-1. The supreme court held that judge is required to considered facts to impose death penalty while jury recommendations can be required under consideration.

Disposition:

The decision of the Hurst case was reversed and the court has demonstrated a decision to consider the facts before making a decision. This decision impacted the on appeal, in progress, and collateral proceedings cases. It also impacted the various capital punishment cases in Florida.

Concurring/Dissenting Opinions:

Justice Alito wrote the dissenting opinion based on Hildwin and Spaziano. He wrote that in Florida jury has an important role in case process, therefore, our decision cannot decide whether they violated the sixth amendment or not.

Commentary:

The case was reversed based on the previous case Ring v. Arizona. It has a social impact as many cases filed appeals based on this case so that their death sentence can be reviewed in a new trial.

Works Cited

ADDIN ZOTERO_BIBL {"uncited":[],"omitted":[],"custom":[]} CSL_BIBLIOGRAPHY Cooke, Brian K., et al. “Revisiting the Decision of Death in Hurst v. Florida.” Journal of the American Academy of Psychiatry and the Law Online, vol. 44, no. 4, Dec. 2016, pp. 483–90.