577 U.S. 92 (2016)
In May 1998, Cynthia Harrison's body was discovered bound, gagged, and stabbed over sixty times in the freezer of the Popeye's restaurant where she worked as an assistant manager.1 The restaurant safe was open and previous day's receipts were missing.2 Florida charged Timothy Lee Hurst, Harrison's co-worker, with first-degree murder.3
At Hurst's trial, the State presented forensic evidence linking him to the crime along with testimony that he had announced plans to rob the restaurant, that he and Harrison were the only employees scheduled to work that day, and that he had disposed of blood-stained evidence and used stolen money to buy shoes and rings.4 Hurst presented an alibi defense, claiming his car broke down and that he heard Harrison sounding scared during a phone call with another person whispering in the background.5 The jury convicted Hurst of first-degree murder without specifying whether it found premeditated murder or felony murder during a robbery.6
Florida law required a separate sentencing proceeding in which the jury rendered an advisory verdict on whether to impose death, after which the judge independently determined the existence of aggravating and mitigating circumstances and imposed the sentence.7 Following the initial trial, the jury recommended death and the judge sentenced Hurst to death, but the Florida Supreme Court later vacated the sentence on postconviction review.8
At the 2012 resentencing hearing, Hurst presented mitigating evidence that he was not a major participant in the murder.9 The advisory jury recommended death by a seven-to-five vote after being instructed it could do so upon finding at least one aggravating circumstance.10 The sentencing judge independently found that the murder was committed during a robbery and was especially heinous, atrocious, or cruel, assigned great weight to these findings and the jury recommendation, and imposed a death sentence.
The Florida Supreme Court affirmed the death sentence by a four-to-three vote.11 The United States Supreme Court granted certiorari to review the case.12
Whether Florida's capital sentencing scheme violates the Sixth Amendment by requiring a judge rather than a jury to find the facts necessary to impose a death sentence?13
The Sixth Amendment right to a jury trial, in conjunction with the Due Process Clause, requires that each element of a crime be proved to a jury beyond a reasonable doubt.14 Any fact that exposes the defendant to a greater punishment than that authorized by the jury's guilty verdict is an element that must be submitted to the jury.15
Yes. Florida law provided that the maximum sentence authorized by the jury's first-degree murder conviction alone was life imprisonment without parole.16 The sentencing judge then independently found the existence of two aggravating circumstances—that the murder was committed during a robbery and that it was especially heinous, atrocious, or cruel—before imposing the death sentence.17 These judge-made findings increased the authorized punishment beyond the jury verdict in the same manner as the Arizona scheme invalidated in Ring v. Arizona.18
Florida's capital sentencing scheme violates the Sixth Amendment because it requires a judge rather than a jury to find the facts necessary to impose a death sentence.19
Related opinions on this issue
Justice Alito dissented on the ground that the Court should not overrule Hildwin and Spaziano without first reconsidering Ring itself.20 The Florida procedure differs materially from the Arizona scheme at issue in Ring because the jury serves as the initial and primary adjudicator of aggravating and mitigating factors.21 Under Florida law the judge performs only a reviewing function and must give the jury recommendation great weight.22
Justice Alito would also have held any error harmless because the evidence supporting both aggravating factors was overwhelming.23