Samuel L. Smithers, Appellant v. State of Florida, Appellee.

Summary

The Florida Supreme Court affirmed the circuit court’s summary denial of Smithers’ first successive post‑conviction relief motion, holding that any error arising under Hurst was harmless beyond a reasonable doubt because the jury’s unanimous death‑sentence recommendation satisfies the constitutional requirement. The Court relied on its prior Davis decision and related precedent. Justice Quince dissented, arguing that the Hurst error could not be harmless where the judge, not the jury, made factual findings.