Mark R. Schlakman, the senior program director at FSU's Center for the Advancement of Human Rights, who served on the American Bar Association's Florida Death Penalty Assessment Team, to the Orlando Sentinel's Darryl E. Owens:
In 2005, then-Supreme Court of Florida Justice Raoul Cantero, who was appointed by Gov. Jeb Bush, wrote a rather remarkable majority opinion for the court in State v. Steele urging the Legislature to revisit Florida's death-penalty statute to require unanimity for recommendations of death. The Legislature essentially has been unresponsive. Cantero has argued that such would help ensure that Florida's death penalty is reserved for the worst of the worst. However, some claim convicted serial killers like Ted Bundy and Aileen Wuornos would have avoided death sentences given less-than-unanimous jury recommendations. Not necessarily so, according to research by Scott Sundby from the University of Miami School of Law, which indicates more rigorous analysis would ensue, changing the nature of the deliberations, conceivably achieving unanimity depending upon the aggravating circumstances.