Hurst Vs. Florida
Case Location: www.supremecourt.gov, https://www.supremecourt.gov/opinions/15pdf/14-7505_5ie6.pdf Hurst Vs. Florida
Timothy Hurst was being tried in court for his supposed killing of his co-worker Cynthia
Harrison. After reviewing the evidence submitted, the jury recommended the death penalty. The
judge participated in some fact finding, and decided Hurst deserved the death sentence, but Hurst
appealed and took part in another sentence hearing. At Hurst’s second court hearing, the jury
again decided that Hurst should receive the death penalty, and the judge again found the facts
prominent enough to decide on the death penalty. It came to the Supreme court because of the
argument that Hurst’s sentence was in violation of the 6th Amendment after the case of Ring v.
Arizona, a case that the Court saw Arizona’s sentencing scheme that allowed a judge instead of
the jury to find the facts needed to sentence the death penalty.
Facts of the Case
On May 2, 1998, at a Popeyes restaurant where both Hurst and Cynthia worked, Cynthia
Harrison’s body was found in the freezer, gagged, bound, and stabbed over 60 times. The safe
in the restaurant was found unlocked, and missing several hundred of dollars, as well as multiple
credit card slips from the previous day. Witnesses stated that Hurst said he was planning on
robbing the restaurant before it occurred, that Hurst and Cynthia were the only employees
scheduled to work at the time of the robbery, and that Hurst got rid of blood-stained evidence
and used the money to buy rings and shoes. Hurst claimed he never made it to work due to his
vehicle malfunctioning. He also claimed he called the restaurant ahead of time to let them know
he would be late. Hurst said Harrison sounded scared when she answered the phone, and that he
could hear whispering, presumably the real murderer, in the background.
The primary issue is whether Florida’s death sentencing scheme to allow the judge
instead of the jury to sentence the defendant to death went against the 6th Amendments right to a
trial by jury or not?
Decision of the Court
Yes, the death penalty sentencing given to Hurst was deemed unconstitutional. The sixth
amendment to the constitution requires a jury, not a judge, to find each fact needed to determine
a death sentence. The judgment of the Supreme Court of Florida was reversed.
Reasoning of the Court
“The sixth amendment to the United States Constitution protects an individual’s right to
an impartial jury. Based on this, Florida was required to base Hurst’s sentence on the jury’s
verdict rather than on the judge’s fact finding. The way Florida sentenced Hurst based on the
judge’s findings of an aggressive instance is unconstitutional.” (Page 10, paragraph 2 Opinion of
the Court, Hurst v. Florida)
Justice Breyer: His view was that “The eighth amendment requires that a jury, not a judge,
make the decision to sentence a defendant to death.” (Page 1, Breyer, J., Concurring in
Judgement, Hurst v. Florida) Justice Breyer states that he would reverse the judgement of
the Florida Supreme Court.
Justice Alito: Justice Alito viewed that there should be no reason to reverse the Florida Supreme
Courts decision on this case for a number of reasons. He quotes a line from Tedder v State,
“…the facts suggesting a sentence of death were so clear and convincing that virtually no
reasonable person could differ.” (Alito, J, dissenting, Page 3 Hurst v. Florida) He brings this
quote up in light of the cruel and tortuous way Cynthia was murdered. The jury was told to
consider how “heinous, atrocious, or cruel” the crime was when deciding on their judgment.
Because the jury found the death sentence to be appropriate after viewing the evidence in this
manner, the judge deciding on their own fact finding to deliver the death sentence was “harmless
beyond a reasonable doubt”, in the eyes of Justice Alito. Justice Alito would rule on the issue of
a harmless error, and would agree with the conclusion of the Florida Supreme Court.
I think, based on the evidence, Hurst should receive the death sentence. The tortuous and
cruel way Cynthia was murdered personally angers me, and I think the death sentence is an
appropriate judgment when considering the crime. But I understand what the implications of
allowing a single person to sentence a defendant to death could bring, e.g. the judge not the jury.
So while I think Hurst should have been given the death penalty, I respect the Supreme Courts
decision to reverse the Florida Supreme Court decision.