In March 2016, Todd barred Jefferson County prosecutors from seeking the death penalty in four cases and declared the state’s death-penalty statute to be unconstitutional. Her decision came in the wake of the U.S. Supreme Court’s January 2016 ruling in Hurst v. Florida striking down Florida’s death penalty scheme on the grounds that it reserved the final authority to determine facts necessary to impose the death penalty to judges, rather than juries. Todd noted in her decision that “Alabama has become a clear outlier” by permitting judges to impose death sentences by overriding jury votes for life and, relying on Hurst, said capital sentences in the state were “being imposed in a wholly unconstitutional manner.”