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Fred Anderson, Jr. v. Florida

Paid petition · Supreme Court of Florida, No. SC18-175 · judgment October 4, 2018


Certiorari denied · October 7, 2019
Pre-decision estimate: 2% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

The Sixth Amendment requires that a jury, not a judge, find every fact necessary to sentence a defendant to death. In Hurst v. Florida, 136 S. Ct. 616 (2016), this Court held that Florida’s capitalsentencing scheme violated the Sixth Amendment because it gave juries only an advisory role. The Court held that the “distinction” between no jury verdict and an “advisory jury verdict” is “immaterial” because the jury did “not make specific factual findings” and the judge thus did not have “the assistance of a jury’s findings of fact” when sentencing. Notwithstanding Hurst’s holding that an advisory jury verdict is tantamount to no jury verdict at all, the Florida Supreme Court has held that every Hurst error is harmless if the advisory jury recommended death by a 12-0 vote because a “jury unanimously [found] all of the necessary facts for the imposition of a death sentence by virtue of its unanimous recommendation.” The questions presented are:

  1. Whether a judge-imposed death sentence that violates Hurst is a structural error requiring reversal of the sentence.

  2. Whether a Hurst violation may automatically be deemed “harmless beyond a reasonable doubt” based solely on the fact that the jury, in an advisory capacity, unanimously recommended a death sentence.

Counsel of record

For petitioner
Elisabeth Susan Theodore
Arnold & Porter Kaye Scholer LLP

For respondent
Amitabh Agarwal
Holland & Knight

Case

Conference history
Distributed for 1 conference

Amicus briefs
3 cert-stage

Linked docket
18A782

Proceedings

  1. Oct 07 2019
    Petition DENIED. Justice Sotomayor, dissenting from the denial of certiorari: I dissent for the reasons set out in Reynolds v. Florida, 586 U. S. ___ (2018) (Sotomayor, J., dissenting).
  2. Sep 04 2019
    DISTRIBUTED for Conference of 10/1/2019.
  3. Sep 04 2019
    Reply of petitioner Fred Anderson Jr. filed. (Distributed)
  4. Aug 15 2019
    Brief of respondent State of Florida in opposition filed.
  5. Jun 27 2019
    Motion to extend the time to file a response is granted and the time is further extended to and including August 15, 2019.
  6. Jun 25 2019
    Motion to extend the time to file a response from July 1, 2019 to August 15, 2019, submitted to The Clerk.
  7. May 16 2019
    Brief amicus curiae of The Rutherford Institute filed.
  8. May 16 2019
    Brief amici curiae of Retired Florida Judges and Jurists filed.
  9. May 15 2019
    Brief amici curiae of Florida Center for Capital Representation at FIU College of Law, et al. filed.
  10. May 10 2019
    Motion to extend the time to file a response is granted and the time is extended to and including July 1, 2019.
  11. May 08 2019
    Motion to extend the time to file a response from May 16, 2019 to July 1, 2019, submitted to The Clerk.
  12. Apr 15 2019
    Petition for a writ of certiorari filed. (Response due May 16, 2019)
  13. Jan 30 2019
    Application (18A782) granted by Justice Thomas extending the time to file until April 13, 2019.
  14. Jan 25 2019
    Application (18A782) to extend the time to file a petition for a writ of certiorari from February 12, 2019 to April 13, 2019, submitted to Justice Thomas.