Edward J. Zakrzewski, II v. State of Florida

Summary

The Supreme Court of Florida affirmed the denial of Edward J. Zakrzewski’s motion for post-conviction relief under Florida Rule of Criminal Procedure 3.851. The court held that his claims based on Hurst v. Florida and Hurst v. State were procedurally barred by the prior denial of similar habeas claims and by the determination that he was not entitled to retroactive application of Hurst. A concurring opinion emphasized that the trial court had overridden the jury’s life recommendation for one of Zakrzewski’s three death sentences.

Holdings

1. The prior denial of Zakrzewski's habeas petition raising similar claims constituted a procedural bar to the claims presented in this appeal.
2. Zakrzewski was not entitled to retroactive application of Hurst, and his claims therefore did not warrant relief.

Questions Presented

1. Whether Zakrzewski was entitled to post-conviction relief based on the retroactive application of Hurst v. Florida and Hurst v. State.
2. Whether Zakrzewski's prior habeas proceeding raising similar Hurst claims constituted a procedural bar to the claims raised in the Rule 3.851 motion.

Disposition

affirmed