Franklin v. State
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The Supreme Court affirmed the postconviction court’s summary denial of Appellant’s postconviction motion to vacate his sentence of death under Fla. R. Crim. P. 3.851, holding that any Hurst error during Appellant’s penalty phase proceedings was harmless beyond a reasonable doubt.
Appellant was convicted of attempted robbery and first-degree murder and sentenced to death. This appeal was from Appellant’s successive postconviction motion in which he claimed that his death sentence was unconstitutional under Hurst v. Florida, 136 S. Ct. 616 (2016) and that his death sentence violated the Eighth Amendment under Hurst v. Florida. The postconviction court denied the motion. The Supreme Court affirmed, holding that the postconviction court properly denied relief on Appellant’s claims.
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