Supreme Court of Florida

Victor Guzman, Appellant v. State of Florida, Appellee

April 6, 201742 Fla. L. Weekly Supp. 419

Summary

The Florida Supreme Court affirmed Victor Guzman’s first‑degree murder conviction, reversed his death‑penalty sentence, and remanded for a new penalty phase. The court held that the trial court did not abuse its discretion in denying mistrial motions, that the State’s closing‑argument remarks did not constitute fundamental error, and that the circumstantial DNA evidence sufficiently proved guilt. The death sentence was vacated because the jury’s recommendation was not unanimous, violating Hurst and Ring precedents.