593 U.S. 255
SCOTUS2021Background
- In 2006 Thedrick Edwards was tried in Louisiana for armed robbery, rape, and kidnapping; Louisiana law then allowed 10-2 or 11-1 guilty verdicts for 12-person juries.
- Edwards was convicted (one count 11–1; other counts 10–2) and sentenced to life; his conviction became final on direct review in March 2011.
- Edwards sought state post-conviction relief and then federal habeas relief claiming the non‑unanimous verdict violated the Sixth Amendment; the federal courts denied relief based on Apodaca v. Oregon.
- While Edwards’ cert petition was pending, this Court decided Ramos v. Louisiana and overruled Apodaca, holding the Sixth Amendment (as incorporated by the Fourteenth Amendment) requires unanimous jury verdicts for serious state crimes.
- The question presented was whether the jury‑unanimity rule announced in Ramos applies retroactively on federal collateral (habeas) review to overturn final convictions like Edwards’.
Issues
| Issue | Plaintiff's Argument (Edwards) | Defendant's Argument (Vannoy/State) | Held |
|---|---|---|---|
| Whether Ramos applies retroactively on federal collateral review | Ramos announced a fundamental jury‑unanimity rule that must apply retroactively to overturn final convictions obtained under non‑unanimous verdicts | Teague v. Lane presumes new procedural rules do not apply retroactively on federal habeas; Ramos is a new procedural rule and therefore not retroactive | Ramos does not apply retroactively on federal collateral review; affirmed (majority opinion) |
| Whether Ramos announced a "new rule" of criminal procedure | Ramos simply recognized the original constitutional meaning, so it is not new for retroactivity purposes | Pre‑Ramos precedent (Apodaca and its understanding) allowed non‑unanimous verdicts; Ramos overruled Apodaca and therefore announced a new rule | Ramos announced a new rule (it repudiated Apodaca and was not dictated by existing precedent) |
| Whether Ramos fits Teague’s "watershed" exception (so would be retroactive) | The unanimity rule is bedrock, prevents inaccurate convictions, and remedies racially discriminatory effects—thus it is watershed | Even important or historic procedural rules (Duncan, Crawford, Batson) were held non‑retroactive; watershed exception is extremely narrow and has not functionally applied | Ramos is not a watershed rule; the Court holds the watershed exception has no practical vitality and thus no new procedural rule will be retroactive on federal collateral review |
| Whether AEDPA independently bars relief | (Edwards) Ramos creates a constitutional right warranting habeas relief despite AEDPA deference rules | Under 28 U.S.C. §2254(d), the state court reasonably relied on Apodaca, so federal relief is barred regardless | Concurring view (Thomas) — AEDPA §2254(d)(1) independently forecloses relief because the state court’s decision was consistent with then‑clearly‑established law |
Key Cases Cited
- Teague v. Lane, 489 U.S. 288 (1989) (establishes non‑retroactivity rule for new procedural rules on federal habeas and the "watershed" exception)
- Apodaca v. Oregon, 406 U.S. 404 (1972) (prior precedent allowing non‑unanimous jury verdicts in state criminal trials; overruled by Ramos)
- Ramos v. Louisiana, 590 U.S. _ (2020) (Court held the Sixth Amendment, as incorporated by the Fourteenth Amendment, requires unanimous jury verdicts in state serious‑offense trials)
- Duncan v. Louisiana, 391 U.S. 145 (1968) (incorporation of the jury‑trial right; cited in retroactivity comparisons)
- Crawford v. Washington, 541 U.S. 36 (2004) (original‑meaning Confrontation Clause decision held non‑retroactive in subsequent precedent)
- Batson v. Kentucky, 476 U.S. 79 (1986) (prohibits race‑based peremptory strikes; retroactivity denied in Allen/Teague line)
- In re Winship, 397 U.S. 358 (1970) (reasonable‑doubt standard; cited in discussion of jury safeguards and retroactivity)
- Burch v. Louisiana, 441 U.S. 130 (1979) (six‑person jury unanimity rule; discussed in retroactivity precedents)