Supreme Court of Florida
Paul Glen Everett, Appellant v. State of Florida, Appellee.
May 24, 2018258 So. 3d 1199
Summary
The court affirmed the summary denial of Everett's successive motion for postconviction relief, holding that any constitutional error in imposing his death sentence was harmless beyond a reasonable doubt because the jury unanimously recommended death. The court relied on its precedent treating a unanimous death recommendation as satisfying the necessary jury findings for purposes of harmless-error review. Justice Quince, dissenting, would have found the error prejudicial because the jury did not make the required factual determination regarding the heinous, atrocious, or cruel aggravator.