Jackson v. State
The Florida Supreme Court affirmed two death sentences imposed after a 2023 Hurst resentencing conducted under the newly amended section 921.141, which allows imposition of death based on an 8-4 jury recommendation. The Court rejected fourteen challenges to the statute and the resentencing proceeding, including facial and as-applied constitutional attacks on nonunanimity (Eighth Amendment, equal protection, bill of attainder), a retroactivity claim under section 775.022(3), a res judicata claim based on the earlier Hurst-relief order, and various unpreserved trial-error claims (Caldwell/jury-instruction, codefendant's life sentence as mitigation, and impeachment of an unavailable witness with prior recantation testimony).
Key facts
- Jackson was convicted of crimes committed in 2005 and originally sentenced to death; he was granted a new sentencing hearing under Hurst v. Florida.
- In 2023, after amendments to Florida Statute section 921.141 took effect allowing death sentences based on an 8-4 jury recommendation, Jackson's resentencing proceeding began and resulted in two death sentences.
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Why it matters
This is the first Florida Supreme Court decision comprehensively addressing constitutional challenges to the 2023 amendments to section 921.141 permitting death sentences based on an 8-4 jury recommendation, making it… — full analysis with a trial
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