Hurst v. Florida

Background

A Florida jury convicted a man, Timothy Hurst, of murdering his co-worker, Cynthia Harrison, after evidence linked him to the crime. At trial the jury found him guilty of first-degree murder but did not specify whether it was premeditated or felony murder. Florida law then required a separate sentencing hearing where an advisory jury recommended death, but the judge held a separate hearing and made written findings of aggravating circumstances before imposing death. At resentencing, the advisory jury recommended death by a 7-to-5 vote, and the judge independently found two aggravating factors and gave those findings great weight in imposing death.

Reasoning

The Court addressed whether the Sixth Amendment (the right to a jury trial) requires a jury, not a judge, to find the facts that make a defendant eligible for the death penalty. Relying on earlier rulings such as Apprendi and Ring, the Court concluded that allowing a judge alone to find aggravating facts that increase the authorized punishment violates the Sixth Amendment. The Court therefore held Florida’s sentencing scheme unconstitutional because the judge, rather than the jury, made the critical factfinding.

Real world impact

The decision means juries must make the factual findings that permit a death sentence, not judges acting alone. The Court reversed the Florida Supreme Court and sent the case back for further proceedings consistent with this ruling. The majority declined to decide whether the error was harmless and left that question to state courts.

Dissents or concurrances

Justice Breyer concurred in the judgment but not the reasoning, citing Eighth Amendment concerns; Justice Alito dissented, arguing the Court should not overrule prior cases and that any error was harmless.