Hunt v. State
In this direct appeal of a first-degree murder conviction and death sentence, the Florida Supreme Court rejected challenges to Florida's newly amended capital sentencing scheme (SB 450), which allows a jury to recommend death with only an 8-4 supermajority rather than unanimity. The Court held the scheme survives Sixth Amendment (Ramos), Eighth Amendment, and Ex Post Facto Clause scrutiny because the unanimity requirement for finding aggravators (the functional 'verdict') remains intact and the change is merely procedural under Dobbert. The Court also upheld admission of extensive collateral 'sex crimes' evidence as inextricably intertwined (not a Williams-rule issue) and approved a transferred-intent instruction where an accomplice shot the wrong victim due to mistaken identity rather than a missed shot at the intended target.
Key facts
- Hunt was convicted of first-degree murder and sentenced to death by jury recommendation in Florida state trial court.
- On direct appeal, Hunt challenged Florida's 2023 amendment (SB 450) allowing death sentences on an 8-4 jury vote rather than unanimity, arguing violations of the Sixth Amendment, Eighth Amendment, and Ex Post Facto Clause.
- +2 more key facts with a free trial
Why it matters
This is one of the first Florida Supreme Court decisions to substantively address and uphold the constitutionality of the 2023 statutory change (SB 450) permitting a non-unanimous 8-4 jury vote to recommend death… — full analysis with a trial
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