Grim v. State
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The Supreme Court affirmed the circuit court’s order summarily denying Appellant’s first successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that any Hurst error in this case was harmless beyond a reasonable doubt.
In 2000, a jury convicted Appellant of first-degree murder and sexual battery upon a person twelve years of age or older with use of a deadly weapon. The jury unanimously recommended the death sentence by a vote of twelve to zero. The Supreme Court affirmed Appellant’s convictions and death sentence on direct appeal. In 2016, Appellant filed his first successive postconviction motion arguing that he was entitled to relief based on Hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). The circuit court summarily denied Appellant’s successive postconviction motion. The Supreme Court affirmed, holding that any Hurst error in this case was harmless beyond a reasonable doubt.
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