State of Florida, Appellant v. Joseph P. Smith, Appellee.

Summary

The Florida Supreme Court held that the error identified in Hurst v. Florida – the jury’s failure to unanimously find all aggravating factors – was not harmless beyond a reasonable doubt, and therefore vacated Joseph P. Smith’s death sentence and remanded the case for a new penalty phase. The Court affirmed the lower court’s order granting the successive motion to vacate the death sentence. Justice Lawson dissented, arguing that the error was harmless and the death sentence should stand.