A U.S. Supreme Court decision striking down Florida’s death-penalty sentencing structure is a “tectonic shift” that should be applied retroactively to all inmates on death row, lawyers for a convicted murderer scheduled to be executed in February wrote in court documents.

Lawyers for Cary Michael Lambrix, who has been on death row for more than three decades, have asked the Florida Supreme Court to halt his execution and allow a lower court to sort out whether the U.S. Supreme Court decision, in a case known as Hurst v. Florida, applies to Lambrix.