Cruz v. State
On remand after a prior reversal for relying on extra-record facts, the trial court again sentenced Cruz to death. The Florida Supreme Court addressed, for the first time post-Lawrence, whether 'relative culpability' review—comparing a capital defendant's sentence to that of an equally culpable codefendant—survives the Court's 2020 elimination of mandatory comparative proportionality review in Lawrence v. State. The Court held that relative culpability review was merely a corollary/component of the now-abolished comparative proportionality review and is therefore likewise eliminated, meaning Cruz's codefendant's life sentence was irrelevant to Cruz's death sentence, which the Court affirmed over a dissent by Justice Labarga.
Key facts
- Cruz was convicted of a capital crime and sentenced to death; his codefendant was charged with the same crime but received a life sentence.
- The trial court re-sentenced Cruz to death on remand after a prior reversal for relying on extra-record facts.
- +2 more key facts with a free trial
Why it matters
This opinion resolves an important open question left by Lawrence v. State regarding the scope of the Florida Supreme Court's reduced appellate review in capital cases, explicitly foreclosing 'relative culpability'… — full analysis with a trial
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