Requirement of Written Orders Before Oral Pronouncement of Death Sentence

In Grossman v. State, 525 So. 2d 833 (Fla. 1988), the Supreme Court of Florida established a procedural rule that "all written orders imposing a death sentence be prepared prior to the oral pronouncement of sentence for filing concurrent with the pronouncement." Id. at 841. The new procedural rule became effective thirty days after the Court's decision became final. See: id. In addition, the court stated that "should a trial court fail to provide timely written findings in a sentencing proceeding taking place after the decision in Grossman, we are compelled to remand for imposition of a life sentence." Stewart v. State, 549 So. 2d 171, 176 (Fla. 1989).