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Florida's sentencing scheme requiring a judge to hold a separate hearing and determine whether sufficient aggravating circumstances existed to justify imposing the death penalty is unconstitutional. The Sixth Amendment requires a jury, not a judge, to find each fact necessary to impose a sentence of death. A jury’s mere recommendation is not enough.
A Florida jury convicted petitioner Timothy Hurst of first-degree murder for killing a co-worker and recommended the death penalty. The court sentenced Hurst to death, but he was granted a new sentencing hearing on appeal. At resentencing, the jury again recommended death, and the judge again found the facts necessary to sentence Hurst to death. The Florida Supreme Court affirmed, rejecting Hurst's argument that his sentence violated the Sixth Amendment in light of Ring v. Arizona, 536 U.S. 584, 122 S. Ct. 2428, 153 L. Ed. 2d 556, in which U.S. Supreme Court found unconstitutional an Arizona capital sentencing scheme that permitted a judge rather than the jury to find the facts necessary to sentence a defendant to death. Hurst challenged the decision.
Did the Florida capital sentencing scheme violate the Sixth Amendment, thereby, making Hurst’s death sentence unconstitutional?
The Court held that the Florida's capital sentencing scheme violates the Sixth Amendment in light of Ring. According to the Court, any fact that would expose the defendant to a greater punishment than that authorized by the jury’s guilty verdict was an “element” that must be submitted to a jury. In the case at bar, Hurst’s death sentence violated the Sixth Amendment where the maximum punishment he could have received without any judge-made findings was life in prison without parole, a judge had increased his authorized punishment based on her own fact-finding, and the existence of an advisory jury verdict did not impact whether Fla. Stat. § 921.141(3) required a judge to make the critical findings necessary to impose the death penalty. Accordingly, the judgment of the lower court was reversed.