QUENTIN MARCUS TRUEHILL
v.
FLORIDA. TERENCE OLIVER V. FLORIDA.
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Florida capital defendants Truehill and Oliver challenged their death sentences on Eighth Amendment grounds, arguing that jury instructions impermissibly diminished jurors' sense of responsibility by repeatedly characterizing their verdict as merely advisory, consistent with the principle established in Caldwell v. Mississippi. The Supreme Court denied certiorari without addressing the claim, prompting Justices Sotomayor, Ginsburg, and Breyer to dissent, arguing that the Florida Supreme Court had failed to reconsider this challenge in light of the Court's intervening decision in Hurst v. Florida, which invalidated Florida's prior capital sentencing scheme, and that the case should have been vacated and remanded for the state court to address the Eighth Amendment issue.
[1] Jury instructions in capital cases that impermissibly diminish the jurors' sense of responsibility for determining the appropriateness of death violate the Eighth Amendme…
[2] A state supreme court's prior ruling on an Eighth Amendment challenge to jury instructions may be undermined by subsequent U.S. …
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In part for the reasons set forth in my opinion in Hurst v. Florida , 577 U.S. ----, ----, 136 S.Ct. 616, 193 L.Ed.2d 504 (2016) (concurring opinion in judgment), I would vacate and remand for the Florida Supreme Court to address the Eighth Amendment issue in these cases. I therefore join the dissenting opinion of Justice SOTOMAYOR in full.
Justice SOTOMAYOR, with whom Justice GINSBURG and Justice BREYER join, dissenting from the denial of certiorari.
At least twice now, capital defendants in Florida have raised an important Eighth Amendment challenge to their death sentences that the Florida Supreme Court has failed to address. Specifically, those capital defendants, petitioners here, argue that the jury instructions in their cases impermissibly diminished the jurors' sense of responsibility as to the ultimate determination of death by repeatedly emphasizing that their verdict was merely advisory. "This Court has always premised its capital punishment decisions on the assumption that a capital sentencing jury recognizes the gravity of its task," and we have thus found unconstitutional under the Eighth Amendment comments that "minimize the jury's sense of responsibility for *4determining the appropriateness of death." Caldwell v. Mississippi , 472 U.S. 320, 341, 105 S.Ct. 2633, 86 L.Ed.2d 231 (1985).
Although the Florida Supreme Court has rejected a Caldwell challenge to its jury instructions in capital cases in the past, it did so in the context of its prior sentencing scheme, where "the court [was] the final decision-maker and the sentencer-not the jury." Combs v. State , 525 So.2d 853, 857 (1988). In Hurst v. Florida , 577 U.S. ----, ----, 136 S.Ct. 616, 624, 193 L.Ed.2d 504 (2016), however, we held that process, "which required the judge alone to find the existence of an aggravating circumstance," to be unconstitutional.
With the rationale underlying its previous rejection of the Caldwell challenge now undermined by this Court in Hurst , petitioners ask that the Florida Supreme Court revisit the question. The Florida Supreme Court, how-ever, did not address that Eighth Amendment challenge.
This Court has not in the past hesitated to vacate and remand a case when a court has failed to address an important question that was raised below. See, e.g., Beer v. United States , 564 U.S. 1050, 131 S.Ct. 2865, 180 L.Ed.2d 909 (2011) (remanding for consideration of unaddressed preclusion claim); Youngblood v. West Virginia , 547 U.S. 867, 126 S.Ct. 2188, 165 L.Ed.2d 269 (2006) (per curiam ) (remanding for consideration of unaddressed claim under Brady v. Maryland , 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963) ). Because petitioners here raised a potentially meritorious Eighth Amendment challenge to their death sentences, and because the stakes in capital cases are too high to ignore such constitutional challenges, I dissent from the Court's refusal to correct that error.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
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Reynolds v. State, 251 So. 3d 811 (Fla. 2018)…of Reynolds's Eighth Amendment claim necessarily fails as well. Other defendants have raised these claims, which we have rejected without discussion. See, e.g. , Truehill v. State , 211 So. 3d 930 (Fla.), cert. denied , --- U.S. ----, 138 S.Ct. 3, 199 L.Ed.2d 272 (2017). In light of the dissenting opinions to the denial of certiorari in Truehill v. Florida , however, we now explicitly address what has already been implicitly decided. The special concurrence takes issue with our viewing this Caldwell claim "…
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Hannon v. State, 228 So. 3d 505 (Fla. 2017)…the circuit court correctly denied Hannon’s third successive motion for postconviction relief. Potential Caldwell5 Claims Hannon directs this Court to a dissent from the denial of certiorari in Truehill v. Florida, Nos. 16-9448, 17-5083, — U.S. -, 138 S.Ct. 3, 199 L.Ed.2d 272, 2017 WL 2463876 (U.S. Oct. 16, 2017), cert. denied, (Sotomayor, J., dissenting). That dissent criticizes this Court for failing to address Eighth Amendment claims under Caldwell. We need not reach that issue in this case, however,…1 / 2
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Lowe v. State, 259 So. 3d 23 (Fla. 2018)…---, 138 S.Ct. 452, 199 L.Ed.2d 334 (2017) ; Tundidor v. State , 221 So. 3d 587, 607-08 (Fla. 2017), cert. denied , --- U.S. ----, 138 S.Ct. 829, 200 L.Ed.2d 326 (2018) ; Oliver v. State , 214 So. 3d 606, 617-18 (Fla.), cert. denied , --- U.S. ----, 138 S.Ct. 3, 199 L.Ed.2d 272 (2017) ; Truehill v. State , 211 So. 3d 930, 956-57 (Fla.), cert. denied , --- U.S. ----, 138 S.Ct. 3, 199 L.Ed.2d 272 (2017). Lowe's arguments do not compel departing from our precedent. Because the Hurst error in Lowe's penalty…1 / 2
Previewing 3 of 16 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963)
- Hurst v. Florida., 136 S. Ct. 616 (U.S. 2016)
- Combs v. State, 525 So. 2d 853 (Fla. 1988)
- Youngblood v. West Virginia, 547 U.S. 867 (U.S. 2006)
- Haque v. Immigration and Customs Enforcement, 564 U.S. 1050 (U.S. 2011)
- Beer v. United States, 564 U.S. 1050 (U.S. 2011)