On December 9, 1993, Jimmy West, a Black man, was killed outside a Jacksonville, Florida, liquor lounge as he and Tamecka Smith were entering a car in the parking lot. The vehicle had been sold to West by his half-brother, Theodore Wright. Michael Bell, seeking revenge for the June 1993 death of his brother Lamar Bell, mistakenly identified the car as still belonging to Wright. Armed with an AK-47, Bell fired twelve bullets into West and four into Smith at point-blank range; both victims died immediately. A third person at the scene escaped unharmed.

Bell then fired into the front of the lounge, endangering about a dozen people waiting to get in, and fled. He was arrested and charged with two counts of first-degree murder. At his March 1995 trial he pleaded not guilty, asserting self-defense and that he believed West was reaching for a weapon; the defense presented no evidence or witnesses. A jury found Bell guilty on both counts and unanimously recommended the death penalty, which the court imposed, citing multiple aggravating circumstances.