Hurst v.

Florida

Facts

Timothy Lee Hurst was charged and convicted of first degree murder for the killing of
Cynthia Harrison. It occurred during a robbery at the Popeyes restaurant at which they both
worked. After being sentenced to death, he appealed his case. Hurst was then granted a new
sentencing trial because the Supreme Court of Florida found that Hursts counsel did not do
enough research on his possible organic brain damage. Once it was proven that Hurst had mental
retardation, he was able to use this as evidence. The jury again gave Hurst a death sentence.
In a precedent case, Ring v. Arizona, The Supreme Court found that the Sixth
Amendment required that the presence of aggravating factors be determined by the jury. The
Supreme Court of Florida had held that this decision did not apply to the Florida death
sentencing scheme, which did not require a jury to determine whether capital defendant is
mentally retarded or to unanimously sentence a defendant to death.

Issue

In light of the Supreme Courts decision in Ring v. Arizona, does the Florida death
sentencing scheme, which does not require a jury to determine whether a capital defendant is
mentally retarded or to unanimously sentence a defendant to death, violate the Sixth
Amendments jury trial guarantee or the Eighth Amendments prohibition against cruel and
unusual punishment?

Judicial Decision and Reasoning

The Supreme Court came to an 8-1 decision in favor of Hurst. They found that Floridas
capital sentencing scheme violated the Sixth Amendment. The Court held that the Sixth
Amendment requires that a jury finds each element necessary to give the death penalty sentence.
Even though the Florida sentencing scheme required that the jury come to a decision and
recommend a death sentence to impose the death penalty, they did not require the judge to
enforce the decision of the jury.

Analysis

This case is important because it sets a very important rule for the death penalty. It
enforces the fact that the judge must follow the jurys recommendation. This is important
because it means that instead of just one person deciding if the defendant is going to be put to
death, there are twelve.