Carl Puiatti v. Florida

CAPITAL CASE In Hurst v. Florida, 136 S. Ct. 616 (2016) (“Hurst I”), this Court held that Florida’s capital sentencing scheme violated the Sixth Amendment because the judge, rather than the jury, made the findings necessary to impose a death sentence. In Hurst v. State, 202 So. 3d 40 (Fla. 2016) (“Hurst II”), the Florida Supreme Court further held that under the Eighth Amendment, the jury’s findings and its ultimate recommendation of a death sentence must be unanimous. The Florida Supreme Court held below that, under Florida law, the Hurst decisions apply retroactively to some final sentences, but not all, crafting a novel partial retroactivity rule that limited the application of Hurst to defendants whose sentences were final after Ring v. Arizona, 536 U.S. 584 (2002). The questions presented are:

1. Whether the decisions in Hurst I and Hurst II announce new substantive rules of federal constitutional law, and if so, whether they must be applied retroactively on state collateral review under the Supremacy Clause and Montgomery v. Louisiana, 136 S. Ct. 718, 729 (2016).

2. Whether the unprecedented partial retroactivity rule adopted by the Florida Supreme Court violates the Eighth and Fourteenth Amendment prohibitions against the arbitrary imposition of death sentences.