Michael Gordon Reynolds, Appellant v. State of Florida, Appellee.

Summary

The Florida Supreme Court affirmed the circuit court's denial of Michael Reynolds's successive post‑conviction motion to vacate his death sentences, holding that any Hurst error was harmless beyond a reasonable doubt and that his Eighth Amendment Caldwell claim failed. The Court reasoned that the jury's unanimous recommendation, the waiver of mitigation, and the proper advisory jury instructions precluded constitutional error. Two dissenting justices argued that the Hurst error was not harmless and that the jury instructions violated Caldwell.