On November 17, 2016, the Florida Supreme Court issued a per curiam opinion in Phillips v. State, a double murder case, reducing the defendant's two death sentences to sentences of life imprisonment on disproportionality grounds.
Under the law applicable at the time of the trial, the jury had recommended death sentences by a vote of 8-4 and the trial judge then made the ultimate sentencing determination. The trial court found three aggravating circumstances: (1) prior violent felony based on the contemporaneous murder of the other victim; (2) capital felony while the defendant was on felony probation (for illegal possession of a controlled substance) and (3) capital felony committed during the commission of a robbery or a burglary. The statutory mitigation found by the trial court was that the defendant was eighteen years old at the time of the crimes. Among the nonstatutory mitigation found by the trial court was that the defendant had a borderline IQ (76), he suffered from a learning disability and a lifelong speech impediment, and he was the victim of childhood neglect. The trial court concluded that the aggravating factors outweighed the mitigating factors
Conducting proportionality analysis on the direct appeal of the convictions and sentences, the Florida Supreme Court held: Our qualitative review reveals that this case is not among the most aggravated and the least mitigated of first-degree murder cases because the the totality of the circumstances includes substantial mitigation that ultimately renders the death penalty disproportionate punishment. The Florida Supreme Court noted that Phillips's mental health mitigation, coupled with the fact that he was eighteen at the time of the murders, constitutes extremely compelling mitigation.