Leo Louis Kaczmar, III v. Florida
In brief
The Supreme Court refused to hear Kaczmar's challenge and denied review, so it did not decide whether Florida's cutoff is constitutional.
- Where it stands
- Decided
Decided · June 18, 2018
- What it’s about
- This case asked whether Florida could deny the benefit of Hurst v. Florida—which said a jury, not a judge, must make the findings needed for a death sentence—to people whose death sentences became final before Ring v.
- Who it affects
- The Supreme Court issued no ruling in this case on whether Florida's cutoff violates the Eighth Amendment or the Fourteenth Amendment's equal-protection guarantee. The order was procedural and did not endorse either side's position.
Summary: written with AI from the case record.

What it's about
Arizona in 2002. Leo Kaczmar argued that Florida’s cutoff rule unconstitutionally treated similarly situated death-row prisoners differently.
The case was part of a larger dispute over whether new constitutional protections for death sentences apply to older cases.
Question presented
1. Whether the Florida Supreme Court’s decision to limit the retroactivity of Hurst v. Florida, 136 S. Ct. 616 (2016), to cases that became final after Ring v. Arizona, 536 U.S. 584 (2002), violates the Eighth and Fourteenth Amendments to the United States Constitution. 2. Whether the Florida Supreme Court’s decision to limit the retroactivity of Hurst v. Florida to cases that became final after Ring v. Arizona violates the Equal Protection Clause of the Fourteenth Amendment.
What the Court decided
Holding
Petition DENIED. Justice Sotomayor, dissenting from the denial of certiorari. (Detached Opinion )
What's next
The Supreme Court has finished handling this request. The record identifies no further Supreme Court step and no ruling on the constitutional questions.
Documents
Opinions
Key filings
Docket activity
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AI analysis generated: Case Briefing
AI analysis generated: Decision Record
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Case data updated: summary, question_presented, generation_metadata
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Opinion added: Opinion
Brief added: Petition
More questions
- What did Kaczmar ask the Supreme Court to review?
- He challenged Florida's cutoff for giving Hurst's jury-protection benefit only to death-sentence cases that became final after Ring v. Arizona in 2002. He argued the cutoff violated the Eighth Amendment and the Fourteenth Amendment's equal-protection guarantee.
- Did the Supreme Court decide whether Florida's cutoff was constitutional?
- No. The Court denied review, so it did not decide the constitutional questions or choose between Kaczmar's and Florida's positions.
- Who disagreed with the decision to deny review in Kaczmar?
- Justice Sotomayor disagreed with refusing to hear the case. The order does not provide a vote count.
- What happens next in Kaczmar's case?
- The Supreme Court's action on his request is complete. The record identifies no further Supreme Court step or ruling on the constitutional questions.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.