Ramos v. Louisiana
Supreme Court of the United States
Argued October 7, 2019
Decided April 20, 2020
Full case nameEvangelisto Ramos, Petitioner v. Louisiana
Docket no.18-5924
Citations590 U.S. ___ (more)
140 S. Ct. 1390, 206 L.Ed.2d 583
ArgumentOral argument
Case history
Prior
  • Defendant convicted of second-degree murder based on 10-to-2 jury verdict, sentenced to life in prison without possibility of parole.
  • Affirmed, State v. Ramos, 231 So. 3d 44 (La. Ct. App. 2017); writs denied, 257 So. 3d 679, 253 So. 3d 1300 (La. 2018).
  • Cert. granted, 139 S. Ct. 1318 (2019).
Questions presented
Whether the Fourteenth Amendment fully incorporates the Sixth Amendment guarantee of a unanimous verdict.
Holding
The Sixth Amendment right to a jury trial—as incorporated against the States by way of the Fourteenth Amendment—requires a unanimous verdict to convict a defendant of a serious offense. Louisiana Court of Appeal, Fourth Circuit reversed.
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Neil Gorsuch · Brett Kavanaugh
Case opinions
MajorityGorsuch (Parts I, II–A, III, and IV–B–1), joined by Ginsburg, Breyer, Sotomayor, Kavanaugh
PluralityGorsuch (Parts II–B, IV–B–2, and V), joined by Ginsburg, Breyer, Sotomayor
PluralityGorsuch (Part IV–A), joined by Ginsburg, Breyer
ConcurrenceSotomayor (all but Part IV–A)
ConcurrenceKavanaugh (in part)
ConcurrenceThomas (in judgment)
DissentAlito, joined by Roberts; Kagan (all but Part III–D)
Laws applied
U.S. Const. amends. VI, XIV
This case overturned a previous ruling or rulings
Apodaca v. Oregon (1972) (plurality opinion), Johnson v. Louisiana (1972) (Powell, J., concurring)

Ramos v. Louisiana, 590 U.S. ___ (2020), was a U.S. Supreme Court decision in which the Court ruled that the Sixth Amendment to the U.S. Constitution requires that guilty verdicts be unanimous in trials for serious crimes. Only cases in Oregon and Louisiana were affected by the ruling because every other state already had this requirement. The decision incorporated the Sixth Amendment requirement for unanimous jury criminal convictions against the states, and thereby overturned the Court's previous decision from the 1972 cases Apodaca v. Oregon[1][2] and Johnson v. Louisiana.[3]

Background

The Sixth Amendment to the United States Constitution defines procedures for prosecution of criminal cases against individuals, parts of which have been incorporated against states by various Supreme Court decisions under the Due Process Clause of the Fourteenth Amendment. The Sixth Amendment assures a jury trial for a person charged on a criminal offense, but does not specify the process around that trial, leaving it for states to define within their own constitutions.[2]

While federal law mandated that a federal jury trial require a unanimous vote to convict a suspect on a criminal charge, the 1972 Supreme Court case Apodaca v. Oregon ruled that states did not have to follow this. All but two states adopted unanimous jury votes to convict. Oregon allowed a jury vote of 10–2 or more for conviction (which Apodaca v. Oregon had challenged), while Louisiana, until 2019, had similarly allowed a 10–2 jury vote to convict (which Johnson v. Louisiana had challenged), but since had passed a new constitutional amendment requiring a unanimous jury vote, applying to all criminal charges placed on January 1, 2019, or later.[2][4]

The present case's petitioner, Evangelisto Ramos, had been convicted of murder in Louisiana on a 10–2 vote in 2016, before the passage of the new constitutional amendment. Ramos appealed the conviction on the issue around the non-unanimous jury factor, arguing that the law, established in 1898, was a Jim Crow law that allowed for racial discrimination within juries.[2][4][5] The Louisiana Court of Appeal, Fourth Circuit upheld his sentence in a November 2017 opinion.[6]

Ramos petitioned to the U.S. Supreme Court on the question "Whether the Fourteenth Amendment fully incorporates the Sixth Amendment guarantee of a unanimous verdict". The Court accepted the case in March 2019.[7] Oral argument for the case was held on October 7, 2019.[5]

Decision

Majority opinions

In a 6–3 decision, the Court reversed the decision against Ramos and ruled that the unanimity of a jury vote for conviction mandated by the Sixth Amendment for serious crimes[8] must also be an incorporated right against the states, overturning Apodaca v. Oregon.[9] Justice Neil Gorsuch wrote the majority opinion, joined in parts by justices Ruth Bader Ginsburg, Sonia Sotomayor, Stephen Breyer, and Brett Kavanaugh, which holds that the guarantee is incorporated by the Due Process Clause of the Fourteenth Amendment. Justice Clarence Thomas joined in the judgment only, arguing instead that it is incorporated by the Privileges or Immunities Clause of the Fourteenth Amendment.[10]

Dissenting opinions

Justice Samuel Alito wrote the dissent joined by Chief Justice John Roberts and in part by Justice Elena Kagan. Alito wrote that the Court should uphold the principle of stare decisis since both Oregon and Louisiana have used the ruling from Apodaca v. Oregon for more than forty years.[2][9]

Subsequent cases

The majority opinion in Ramos v. Louisiana considered whether prisoners may seek collateral review to challenge non-unanimous convictions, but declined to decide the issue.[11] While all defendants who had not yet exhausted their appeals were expected to be granted new trials, the Supreme Court did not address the issue of whether or not defendants who had exhausted all appeals can be covered by Ramos.

Thedrick Edwards, a different Louisiana inmate convicted 10–2, had been challenging Louisiana's non-unanimous jury conviction law since his own 2007 conviction, had petitioned to the Supreme Court around the same time that Ramos had been under consideration, using collateral review (Ramos dealt with direct review).[12] Following the decision of Ramos, Edwards altered his petition to the Supreme Court to ask if the Ramos decision should be held retroactively to defendants who had already exhausted all appeals. The court accepted Edwards' case under Edwards v. Vannoy, and oral arguments were held on December 2, 2020.[13]

On May 17, 2021, the Supreme Court ruled that the Ramos jury-unanimity rule does not apply retroactively on federal collateral review.[14] Subsequently, the Oregon Supreme Court ruled in December 2022 that the Ramos decision should be applied retroactively to cases within the state.[15]

References

  1. ↑ Ramos v. Louisiana, No. 18-5924, 590 U.S. ___ (2020).
  2. 1 2 3 4 5 de Vogue, Ariana (April 20, 2020). "Supreme Court says unanimous jury verdicts required in state criminal trials for serious offenses". CNN. Retrieved April 20, 2020.
  3. ↑ "Johnson v. Louisiana, 406 U.S. 356 (1972)". Justia Law. Retrieved April 22, 2022.
  4. 1 2 Lopez, German (November 6, 2018). "Louisiana votes to eliminate Jim Crow jury law with Amendment 2". Vox. Retrieved April 20, 2020.
  5. 1 2 Liptak, Adam (October 7, 2019). "Supreme Court Weighs Ending Non-Unanimous Jury Verdicts in Criminal Cases". The New York Times. Retrieved April 20, 2020.
  6. ↑ State v. Ramos, 231 So. 3d 44 (La. Ct. App. 2017).
  7. ↑ Barnes, Robert (March 28, 2019). "Supreme Court to examine whether unanimous juries are required for criminal convictions". The Washington Post. Retrieved April 23, 2020.
  8. ↑ Liptak, Adam (April 20, 2020). "Supreme Court Bans Non-Unanimous Jury Verdicts for Serious Crimes". The New York Times. Retrieved January 23, 2023.
  9. 1 2 Rubin, Jordan S. (April 20, 2020). "Supreme Court Bolsters Unanimous Jury Rule in Louisiana Case (3)". Bloomberg Law. Bloomberg Law. Archived from the original on April 28, 2020. Retrieved July 10, 2020.
  10. ↑ Volokh, Eugene (April 20, 2020). "Constitution Requires Unanimous Criminal Jury Verdicts for Conviction". Reason. Retrieved April 20, 2020.
  11. ↑ Blackman, Josh (April 21, 2020). "5 Unanswered Questions from Ramos v. Louisiana". Reason.com. Retrieved October 21, 2020.
  12. ↑ Rubin, Jordan S. (December 2, 2020). "Justices Divided on Making Jury Unanimity Decision Retroactive (1)". Bloomberg Law. Retrieved March 24, 2021.
  13. ↑ Barnes, Robert (December 2, 2020). "Supreme Court weighs whether its ruling requiring unanimous juries should be applied retroactively". The Washington Post. Retrieved December 3, 2020.
  14. ↑ Simerman, John (May 17, 2021). "U.S. Supreme Court refuses to make Louisiana ban on non-unanimous juries retroactive". The Times-Picayune/The New Orleans Advocate. Retrieved May 17, 2021.
  15. ↑ Sparling, Zane (December 30, 2022). "Hundreds of Oregon criminal convictions overturned due to nonunanimous jury verdicts, Supreme Court decides". The Oregonian. Retrieved January 7, 2023.
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