Rodney Renard Newberry v. State of Florida

Summary

The Supreme Court of Florida affirmed Rodney Renard Newberry’s convictions for first-degree premeditated murder, felony murder, and armed robbery. Applying Hurst v. Florida, the court held that the 8-to-4 jury recommendation rendered the death sentence unconstitutional and vacated the sentence, remanding for a new penalty phase.

Holdings

1. Competent, substantial evidence supported Newberry's convictions for first-degree premeditated and felony murder.
2. Newberry's death sentence violated Hurst because the jury recommended death by a vote of eight to four, so the court could not determine that the jury unanimously found the aggravating circumstances outweighed the mitigating circumstances.
3. The Hurst error was not harmless beyond a reasonable doubt.

Questions Presented

1. Whether competent, substantial evidence supported Newberry's convictions for first-degree premeditated murder and felony murder.
2. Whether Newberry's death sentence violated Hurst v. Florida and Hurst v. State because the jury recommended death by a nonunanimous eight-to-four vote.
3. Whether the Hurst sentencing error was harmless beyond a reasonable doubt.

Disposition

reversed_and_remanded