Hurst v. Florida

A capital sentencing proceeding that allows a judge, and not the jury, to make the final determination in imposing the death penalty violates the Sixth Amendment.

Petitioner challenged Florida’s hybrid sentencing proceedings, arguing it violates the Sixth Amendment in light of Ring v. Arizona, which expanded Apprendi v. New Jersey. Apprendi, established that any facts that “expose the defendant to a greater punishment than that authorized by the jury’s guilty verdict is an element that must be submitted to the jury.” Here, Petitioner was convicted of murdering his coworker. The jury recommended that Petitioner be sentenced to death. Under Florida law, a judge is required to make a separate determination as to “whether sufficient aggravating circumstances existed to justify imposing the death penalty.” The judge, found that aggravating circumstances existed, and sentenced Petitioner to death. The Court held that Florida’s sentencing scheme is unconstitutional under the Sixth Amendment, and that the mere recommendation by a jury does not meet the Apprendi standard. Following the analysis in Ring, the Court noted that requiring the trial judge to make the critical fact finding, and allowing the trial judge to make the ultimate decision on imposing a death sentence is unconstitutional. The Court concluded by overruling in part Spaziano and Haldwin each of which held “the Sixth Amendment does not require specific findings authorizing the imposition of the sentence of death be made by the jury.” The decisions are overruled to the extent they allow a sentencing judge to make the ultimate decision regarding aggravating circumstances, and participate in independent fact finding to impose the death penalty.