Tisdale v. StateAnnotate this Case
The Supreme Court vacated Defendant’s death sentence and remanded this case to the trial court for a new penalty phase, holding that the error pursuant to Hurst v. State, 202 So. 3d 40 (Fla. 2016), was not harmless beyond a reasonable doubt.
Defendant was convicted of first-degree murder of a law enforcement officer and other crimes. The jury recommended a sentence of death by a vote of nine to three on the murder charge. The trial court imposed a death sentence on the murder charge and lesser sentences on the other charges. Defendant appealed, arguing that he was entitled to a new penalty phase pursuant to Hurst. The Supreme Court agreed, vacated Defendant’s death sentence but affirmed his convictions and sentences on all lesser charges, holding that Hurst-related precedent required reversal of Defendant’s death sentence.