Conahan v. State
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The Supreme Court affirmed the postconviction court’s denial of Appellant’s successive motion to vacate judgments of conviction, including one of first-degree murder, and sentence of death under Fla. R. Crim. P. 3.851, holding that Appellant was not entitled to relief.
Specifically, the Supreme Court held (1) Hurst v. Florida, 136 S. Ct. 616 (2016) and Hurst v. State, 202 So. 3d 40 (Fla. 2016) were applicable to Appellant’s case, but the Hurst error in this case was harmless beyond a reasonable doubt; and (2) Appellant was not entitled to relief on his Hurst-induced claim under Caldwell v. Mississippi, 472 U.S. 320 (1985), or his claim that he was entitled to application of chapter 2017-1, Laws of Florida.
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