Snelgrove v. State
Annotate this CaseThe Florida Supreme Court vacated David Beasher Snelgrove’s two death sentences and ordered that Snelgrove receive a new penalty phase proceeding based on the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. (2016) and this court’s decision in Hurst v. State, 202 So. 3d 40 (Fla. 2016). After a second penalty phase, the trial court followed the jury’s nonunanimous recommendation of death sentences for Defendant’s two murder convictions. Here, Snelgrove appealed the denial of his petition for postconviction relief pursuant to Fla. R. Crim. P. 3.851 and also petitioned the Florida Supreme Court for a writ of habeas corpus. The court affirmed the denial of Snelgrove’s rule 3.851 motion and denied the petition for writ of habeas corpus but vacated his death sentences, holding that Hurst was applicable in this case and that the failure to require a unanimous jury recommendation was not harmless beyond a reasonable doubt. The court remanded the cause for a new penalty phase.
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