Lancelot Uriley Armstrong, Appellant v. State of Florida, Appellee; Lancelot Uriley Armstrong, Petitioner, v. Julie…

Summary

The Florida Supreme Court vacated Lancelot Uriley Armstrong’s death sentence, holding that the Hurst error—stemming from a non‑unanimous jury recommendation—was not harmless beyond a reasonable doubt, and remanded for a new penalty phase. The Court applied the Chapman harmless‑error standard and found the state could not meet its burden. Justice Perry, in a concurring‑in‑part/dissent‑in‑part opinion, agreed the error was not harmless but argued the case should be remanded for a life‑sentence rather than a new penalty phase.