On January 23, 2020, the Florida Supreme Court reversed a grant of sentencing relief to Florida death row inmate Mark Poole. State v. Poole, ___ So.3d ___ (Fla. Jan. 23, 2020). The post-conviction court had granted relief based on its application of Hurst v. State, 202 So.3d 40,57 (Fla. 2016), which had held: "[B]efore the trial judge may consider imposing a sentence of death, the jury in a capital case must unanimously and expressly find all the aggravating factors that were proven beyond a reasonable doubt, unanimously find that the aggravating factors are sufficient to impose death, unanimously find that the aggravating factors outweigh the mitigating factors, and unanimously recommend a sentence of death." Poole's sentencing jury had not been unanimous as to the death sentence and the post-conviction court concluded that the Hurst violation was not harmless beyond a reasonable doubt. The Florida Supreme Court revisited its earlier decision and "recede[s] from Hurst v. State except to the extent that it held that a jury must unanimously find the existence of a statutory aggravating circumstance beyond a reasonable doubt." This holding does not impact the revised Florida statute that now requires jury unanimity for a death sentence.