News Brief — Florida Supreme Court Denies Relief in Two More Jury Non-Unanimity Cases

NEWS (3/19/20): Florida — The Florida Supreme Court has denied new sentencing hearings to two more death-row prisoners who were sentenced to death after non-unanimous sentencing recommendations by their juries. Relying on the court’s January 23, 2020 decision in State v. Poole that abandoned its requirement of unanimous sentencing recommendations, the court upheld death sentences imposed on Grover Reed and Lucious Boyd.

Reed would have been denied relief under the court’s prior jury unanimity caselaw because his conviction became final before Ring v. Arizona was decided in June 2002, the cutoff the court had established for applying its jury unanimity requirement. Boyd was denied a new sentencing hearing under Poole’s ruling that a death sentence is constitutional if the jury unanimously voted to convict a defendant of an additional charge that also constituted an aggravating circumstance that would make the defendant eligible for the death penalty.