Steele was being tried for murder when his attorney argued that Florida's death penalty statute violates the U.S. Supreme Court's decision in Ring v. Arizona. The trial court disagreed, but then ordered that the state must provide the defense with notice about all aggravating factors it intends to prove in the penalty phase. It also ordered that jury members be given a special jury verdict form to indicate each aggravating factor they might find and the jury vote on each. On appeal, the Second District found that the required notice by the state violated the essential requirements of the law while the special verdict form did not. Recognizing the potential statewide impact of its ruling, the Second District also certified the questions to the Florida Supreme Court.