Supreme Court of Florida
Elijah Brookins, Appellant v. State of Florida, Appellee
April 20, 2017228 So. 3d 31
Summary
The court affirmed Brookins's first-degree murder conviction, concluding that the collateral-crime impeachment evidence and the State's questioning about his failure to identify the alleged killer did not warrant relief, and that the evidence was sufficient. It held that the nonunanimous death recommendation violated the applicable jury-trial requirement and that the State failed to establish harmlessness beyond a reasonable doubt, requiring a new penalty phase. Lawson, J., concurring in part and dissenting in part, would have upheld the death sentence because Brookins's prior violent felony conviction eliminated any sentencing error.