Supreme Court of Florida

Edward J. Zakrzewski, Ii, Appellant v. State of Florida, Appellee.

September 20, 2018254 So. 3d 324

Summary

The Florida Supreme Court affirmed the circuit court's denial of Zakrzewski's post‑conviction motion, holding that the prior denial of his habeas petition bars the present claims and that the Hurst decision does not apply retroactively to his case. The Court also noted, as obiter, that jury overrides are unconstitutional under Hurst and Florida law.