Supreme Court of Florida

Lenard James Philmore v. State of Florida

January 25, 2018

Summary

The Florida Supreme Court affirmed the post‑conviction court’s denial of relief for Lenard James Philmore, holding that any Hurst error was harmless beyond a reasonable doubt, that his due‑process and Eighth Amendment claims were barred, that the Batson claim could not be relitigated, and that Hurst applies retroactively. The Court based its decision on the unanimous jury recommendation, the confession, and the aggravating circumstances.