Simmons v. State
Annotate this CaseDefendant was convicted of the kidnapping, sexual battery, and death of Deborah Tressler. Defendant was sentenced to death after a unanimous jury recommendation in the first penalty phase. The Supreme Court ultimately vacated the sentence of death and remanded for a new sentencing proceeding because Defendant’s counsel failed fully to investigate and present mitigating evidence regarding Defendant’s mental health and childhood. After a new penalty phase, the jury returned a special interrogatory verdict indicating a unanimous finding that three aggravating factors were established beyond a reasonable doubt. The jury issued an advisory sentencing recommending death. The trial court entered a sentencing order imposing the death sentence after a Spencer hearing. Defendant appealed. Shortly before oral argument was held in this case, the United States Supreme Court decided Hurst v. Florida. The Florida Supreme Court vacated Defendant’s sentence of death and remanded the case to the trial court for a new penalty phase proceeding, holding (1) in accordance with Hurst, the jury did not unanimously conclude that the aggravating factors were sufficient or that the aggravating factors outweighed the mitigating circumstances; and (2) it cannot be said beyond a reasonable doubt that there was no possibility that the Hurst error contributed to the jury recommendation of death in this case.
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