Rodney Tyrone Lowe, Appellant v. State of Florida, Appellee. — Quince, J., Concurring in Part and Dissenting in Part

Summary

Justice Quince, concurring in part and dissenting in part, argues that the trial‑court errors—failure to fully inform the jury about Florida’s parole system and credit for time served, improper references to Lowe’s prior death sentence, and the jury’s lack of unanimous finding on the avoid‑arrest aggravator—are not harmless beyond a reasonable doubt and therefore require vacating the death sentence and remanding for a new penalty phase. The opinion does not adopt the majority’s conclusion that the errors were harmless. The dissent is joined by Justice Lewis and references Hurst’s post‑Hurst harmless‑error framework.