Miguel Oyola v. State of Florida

Summary

The Florida Supreme Court reversed and remanded Miguel Oyóla’s second revised sentencing order because the trial judge improperly relied on a nonstatutory aggravating factor and denigrated the defendant’s mental‑health mitigation, errors that were not harmless. The Court held that these errors required a new penalty‑phase proceeding under the statutory scheme. Justice Polston dissented, arguing the extraneous language did not require reversal.