Richard Harold Anderson v. State of Florida

Summary

The Supreme Court of Florida affirmed the denial of Richard Harold Anderson’s motion for post-conviction relief under Florida Rule of Criminal Procedure 3.851. The court held that Hurst v. Florida did not apply retroactively to Anderson’s death sentence, which became final in 1991, relying on Hitchcock v. State.

Holdings

1. Hurst does not apply retroactively to Anderson's death sentence because the sentence became final in 1991.
2. The circuit court correctly denied Anderson's motion for post-conviction relief.

Questions Presented

1. Whether Hurst v. Florida and Hurst v. State apply retroactively to Anderson's death sentence, which became final in 1991.
2. Whether the circuit court properly denied Anderson's Rule 3.851 motion for post-conviction relief.

Disposition

affirmed