Hurst v. Florida
United States Supreme Court
136 S.Ct. 616 (2016)
Timothy Hurst (defendant) was convicted of first-degree murder by a Florida jury, which then rendered only an advisory death-penalty recommendation without specifying any factual findings; following Florida's statutory process, the trial judge separately conducted a sentencing hearing and made the written factual findings necessary to actually impose the death sentence. After the Florida Supreme Court reversed and ordered another sentencing hearing that produced the same outcome (advisory jury recommendation followed by judicial fact-finding and a death sentence), Hurst petitioned for Supreme Court review, arguing the process violated his Sixth Amendment jury-trial right as recently clarified in Ring v. Arizona, which had struck down a similar Arizona scheme letting a judge alone find the aggravating circumstances needed for death.
Whether a capital sentencing scheme that has the jury render only an advisory recommendation, while the judge alone makes the specific factual findings necessary to impose the death penalty, satisfies the Sixth Amendment right to a jury trial.