14 January 2018 :
The Florida Supreme Court has reversed one more death sentence imposed by trial judges after juries had reached non-unanimous sentencing recommendations. The court granted new penalty-phase hearings to Vahtiece Alfonzo Kirkman, sentenced to death in 2016 in Brevard County. Two jurors had voted for life. In Hurst v. State, the Florida court ruled that the Florida constitution required that a jury return a unanimous verdict for death before the trial judge could impose a death sentence.