Jonathan Huey Lawrence v. State of Florida

Summary

The court affirmed Lawrence’s death sentence and held that the Florida Constitution’s conformity clause prohibits judicial comparative proportionality review of death sentences unless the Legislature expressly requires it by statute. The court receded from its prior requirement of comparative proportionality review and removed that review from the scope of its appellate review rule. The court also rejected Lawrence’s claim that the trial court fundamentally erred by failing to determine beyond a reasonable doubt that the aggravating circumstances outweighed mitigation.