No. 17-8148October Term 2017Decided Jun 18, 2018
Leo Louis Kaczmar, III, Petitioner v. Florida
The Supreme Court did not take the case, so Florida's limit on Hurst retroactivity stayed in effect for Kaczmar.
Case status
- Current stage
- Decided
- Latest event
- Decision released Jun 18, 2018
- What it's about
from the Supreme Court of Florida.
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.
- Case path
Supreme Court of Florida / Decision released Jun 18, 2018
- Area
Civil Rights
Briefing
What it's about
Kaczmar asked the Supreme Court to review Florida's rule that made Hurst v. Florida retroactive only for death-penalty cases that became final after Ring v. Arizona. On June 18, 2018, the Court declined review and left the Florida Supreme Court's decision in place without deciding the merits.
Vote
The Court declined review. The prompt does not provide a vote breakdown or any separate writings.
Impact
That meant Florida inmates whose cases became final before Ring did not get help from this petition. For example, a prisoner arguing that a jury, not a judge, should have made key death-sentencing findings could not use this case to reopen a final sentence.
What's next
There is no further action in this Supreme Court docket. The lower-court ruling remains in place because the justices chose not to hear the case.
What was the main dispute in Kaczmar v. Florida?
Kaczmar challenged Florida's rule that Hurst applied retroactively only to cases final after Ring. He said that limit violated the Eighth Amendment, due process, and equal protection.
Who was most affected by the Court's refusal to hear the case?
Florida death-row inmates whose cases became final before Ring were most affected. They could not use this petition to seek relief under Hurst.
What was the next procedural step after the Supreme Court acted?
There was no next Supreme Court step in this docket. The Florida Supreme Court's ruling stayed in place because review was denied.
Decision
What the Court decided
The Supreme Court did not take the case, so Florida's limit on Hurst retroactivity stayed in effect for Kaczmar.
Impact
That meant Florida inmates whose cases became final before Ring did not get help from this petition. For example, a prisoner arguing that a jury, not a judge, should have made key death-sentencing findings could not use this case to reopen a final sentence.
Not official Court text.
Opinion documents
Documents
Related cases




Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Jun 1, 2026
- Method
- Methodology