Florida Supreme Court
Case No. SC18-245
Jan 2020

State vs. Poole

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Case Details

Decision

In a 4-1 decision, the ruling partly reverses a 2016 ruling by the same Court, Hurst v. State (Hurst). That ruling was informed by a U.S. Supreme Court decision, Hurst vs. Florida. Specifically for Poole, the ruling reverses the lower court's order to cancel his death sentence, rejects his request for a new trial, and sends the case back to the lower court to reinstate his sentence. The ruling reads:

"Without legal justification, this Court used [U.S. Supreme Court ruling] Hurst v. Florida—a narrow and predictable ruling that should have had limited [impact on] the death penalty in our state as an occasion to disregard decades of settled Supreme Court and Florida precedent."

The state of Florida appealed the reversal of Poole's death sentence, asking the Court to re-examine and partially change the Hurst ruling. Poole also filed for appeal asking for a new trial.

As requested by the State, the Court reviewed the Hurst decision. Among other things, Hurst made it necessary to have a unanimous jury recommendation for death in order for a judge to sentence a defendant to death.

The majority of the Court finds that the Hurst ruling misunderstood instructions from the U.S. Supreme Court. No court ruling or law forced the Court to give power to the jury's death penalty recommendation in the federal Hurst v. Florida ruling. They also say that the Hurst ruling departed from precedent.

The opinion points out the Florida Legislature updated the sentencing law in response to the Hurst decision. It did not question the validity of the update, but says that this ruling has restored the Legislature's "discretion" on the matter.

Dissent: Justice Labarga

"In the strongest possible terms, I dissent ... this Court has taken a giant step backward and removed a significant safeguard for the just application of the death penalty in Florida."

Labarga's objects, saying that the ruling:  

  • makes Florida 1 of only 2 states that do not require a unanimous jury recommendation to sentence someone to death.
  • is at odds with the federal death penalty law.
  • removes an important safeguard to make sure the death penalty is only applied for the worst murders.

He disagrees that Hurst broke with precedent. Florida has required unanimous jury verdicts for more than a century. It "defies reason" to then to reduce the jury's role when it comes to whether or not punishment should include death.

He denies that Hurst removed the Legislature's "discretion". He argues that it is the Court's responsibility to interpret the law. In Florida, it is only this Court that can determine if Florida's death penalty laws are constitutional or not.

Concurring Specially: Justice Lawson

"... it is clear that Poole suffered no constitutional deprivation in ... his sentence and that we cannot reach a correct legal result ... without receding in part from Hurst v. State."

Justice Lawson writes against Justice Labarga's dissent. He reasons that:

  • federal laws and other states' laws are irrelevant.
  • the Legislature updated the sentencing laws to match the Hurst ruling. Florida will require unanimous jury recommendations unless the Legislature updates the law again.
  • Labarga's assertion that there was precedent to uphold Hurst is not accurate.
  • he sees safeguards in the sentencing and appeals processes, so he does not believe a safeguard has been eliminated.
Read the full ruling at 5cda.org

Background

In an 11-1 vote, the the jury recommended the death penalty for Mark Anthony Poole, and the judge sentenced him to death. In appeal, the Florida Supreme Court upheld that ruling (2015).

In 2016, the Florida Supreme Court ruled in Hurst v. State that juries must unanimously vote for the death penalty in order for it to be a valid sentence. The trial court reversed Poole's death sentence because it violated Hurst.

Related Articles

Summary from the American Bar Association, 3/2020

Editorial: ($) A Death Court Sits at Tallahassee | South Florida Sun Sentinel | 6/2020

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