State v. PooleAnnotate this Case
The Supreme Court affirmed in part and reversed in part the trial court's judgment ordering a new penalty phase proceeding after finding Defendant was entitled to relief under Hurst v. State, 202 So. 3d 40 (Fla. 2016), and rejecting Defendant's guilt-phase claim, holding that this Court must partially recede from Hurst.
The jury in Defendant's case recommended death by a vote of eleven to one after unanimously finding that, during the course of the first-degree murder, Defendant committed related crimes. Defendant later filed his postconviction motion alleging that counsel was ineffective for conceding that Defendant committed the nonhomicide offenses for which he was convicted and that Defendant was entitled to resentencing because the jury did not make the findings required by Hurst. The trial court denied Defendant's ineffective assistance of counsel claim but vacated Defendant's death sentence pursuant to Hurst. The Supreme Court reversed in part, holding (1) this Court recedes from Hurst except to the extent it requires a jury unanimously to find the existence of a statutory aggravating circumstance; and (2) under a correct understanding of Hurst v. Florida, 136 S. Ct. 616 (2016), the requirement that a jury unanimously find a statutory aggravating circumstance beyond a reasonable doubt was satisfied in this case.