Supreme Court of Florida
Jesse Guardado, Petitioner v. Julie L. Jones
May 11, 201742 Fla. L. Weekly Supp. 552
Summary
The court denied Guardado’s habeas petition seeking relief based on Hurst, holding that any Hurst error was harmless beyond a reasonable doubt because the jury unanimously recommended death. The court relied on the unanimous recommendation as establishing the necessary findings for imposing the death sentence. Justice Quince, dissenting, would have held that the Hurst error was not harmless because the jury did not make each factual determination required for death.