Hurst v. Florida

Background

A Florida jury convicted Timothy Hurst of killing his co‑worker, who was found bound and stabbed many times. At trial the jury found him guilty of first‑degree murder but did not specify the theory. Under Florida law, a separate sentencing hearing is held where a jury gives an advisory recommendation of death or life. Even though the jury recommended death by a 7–5 vote at resentencing, the judge held a hearing, independently found two aggravating factors (robbery and heinousness), and imposed death.

Reasoning

The Court asked whether the Sixth Amendment requires a jury, not a judge, to find the facts that make a defendant eligible for death. Relying on earlier rulings saying any fact that increases punishment is an element to be found by a jury, the majority held that Florida’s scheme unlawfully lets a judge increase the maximum sentence through independent factfinding. The Court said the advisory jury does not substitute for a jury finding and overruled parts of prior Florida‑friendly decisions (Spaziano and Hildwin) that allowed judicial factfinding.

Real world impact

The ruling means Florida judges can no longer rely on their own factfinding to make defendants death‑eligible; juries must find the aggravating facts. The Court reversed the Florida Supreme Court and sent the case back for further proceedings. The Justices declined to decide whether the error was harmless, leaving that issue for state courts to consider.

Dissents or concurrances

Justice Breyer agreed with the outcome but not the majority’s reasoning, saying the Eighth Amendment requires jury decision. Justice Alito dissented, arguing the Court should not overrule prior cases and that any error was harmless given the strong evidence of aggravators.