Reed v. State
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The Supreme Court affirmed the order of the trial court denying Appellant's successive postconviction motion filed pursuant to Fla. R. Crim. P. 3.851 seeking relief from his sentence of death pursuant to Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016), holding that State v. Poole, 45 Fla. L. Weekly S41 (Fla. Jan. 23, 2020), was dispositive in this case.
Appellant's death sentence became final in 1990, before the Supreme Court decided Ring v. Arizona, 536 U.S. 584 (2002). The Supreme Court subsequently decided Poole, pursuant to which there was no Hurst error in Appellant's case because a unanimous jury finding establishes the existence of at least one statutory aggravating circumstance beyond a reasonable doubt. In the instant case, the Supreme Court held that two of the four statutory aggravating circumstances found by the trial court - that the capital felony was committed during the commission of a sexual battery and for pecuniary gain - were established because Appellant's jury found him guilty of the contemporaneous crimes of sexual battery and robbery.
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