Ramos v. Louisiana
590 U.S. 83
| SCOTUS | 2020Background
- Evangelisto Ramos was convicted in Louisiana of a serious felony by a 10–2 jury verdict and sentenced to life without parole; he challenged the nonunanimous verdict as violating the Sixth Amendment.
- Louisiana and Oregon were the only U.S. jurisdictions permitting nonunanimous felony convictions (10–2 or 11–1); those rules trace to late-19th/early-20th-century origins that courts have acknowledged were tied to racial exclusionist aims.
- The question presented: whether the Sixth Amendment right to a trial "by an impartial jury," as incorporated against the States by the Fourteenth Amendment, requires a unanimous verdict to convict in serious offenses.
- The Court granted certiorari to resolve conflicting precedent stemming from Apodaca v. Oregon and Johnson v. Louisiana (1972), which produced fractured opinions sustaining nonunanimous state convictions.
- The Supreme Court (majority) reversed Ramos’s conviction, holding that the Sixth Amendment requires unanimous jury verdicts to convict for serious offenses and that this protection applies against the States via the Fourteenth Amendment.
Issues
| Issue | Plaintiff's Argument (Ramos) | Defendant's Argument (Louisiana) | Held |
|---|---|---|---|
| Whether the Sixth Amendment requires a unanimous jury verdict to convict of a serious offense | The Sixth Amendment’s guarantee of "trial by an impartial jury" incorporates the common-law unanimity requirement; long-standing treatises and case law support unanimity | Apodaca left the question open; earlier statements requiring unanimity were dicta or surplusage and the Amendment’s drafting choices show the framers omitted explicit unanimity | The Sixth Amendment requires unanimous verdicts for serious criminal convictions; unanimity is part of the incorporated jury-trial right |
| Whether the unanimity requirement applies equally to States via incorporation | Cite Duncan and incorporation doctrine: incorporated rights retain the same content against States as federal government | Apodaca’s fractured opinions (including Powell’s dual-track view) permit a different rule for States; stare decisis supports Apodaca | The unanimity requirement is incorporated against the States by the Fourteenth Amendment (majority opinion) |
| Whether Apodaca remains controlling precedent under stare decisis | Apodaca was wrongly decided, conflicted with 120+ years of precedent and history, and its fractured reasoning lacks force; overruling is justified | Apodaca produced longstanding reliance in Louisiana and Oregon and the decision should not be disturbed; precedent and reliance favor retention | Court overruled Apodaca (majority): stare decisis factors (reasoning quality, consistency, reliance) favored overruling |
| Remedies / retroactivity for convictions already final or on collateral review | Ramos sought reversal of his conviction; broader remedy questions reserved for later cases | States warned of retrials and collateral-litigation tsunami; reliance interests argue for limiting or nonretroactivity | Court reversed on direct review; retroactivity on collateral review left for future litigation under Teague framework (majority anticipates limited retroactivity) |
Key Cases Cited
- Thompson v. Utah, 170 U.S. 343 (1898) (early statement that jury conviction requires unanimous verdict)
- Patton v. United States, 281 U.S. 276 (1930) (describing unanimity as an element of the jury trial right)
- Andres v. United States, 333 U.S. 740 (1948) (affirming unanimity requirement where Bill of Rights applies)
- Duncan v. Louisiana, 391 U.S. 145 (1968) (Sixth Amendment jury right incorporated against the States)
- Apodaca v. Oregon, 406 U.S. 404 (1972) (plurality and fractured opinions upholding nonunanimous state convictions)
- Johnson v. Louisiana, 406 U.S. 356 (1972) (companion case to Apodaca addressing state nonunanimous verdicts)
- Marks v. United States, 430 U.S. 188 (1977) (framework for identifying controlling rationale in fractured decisions)
- Teague v. Lane, 489 U.S. 288 (1989) (retroactivity rule for new procedural rules on collateral review)
- United States v. Booker, 543 U.S. 220 (2005) (example of large remedial impact when a constitutional rule changes)
- Mapp v. Ohio, 367 U.S. 643 (1961) (illustrative incorporation-era precedent affecting criminal procedure)
- Miranda v. Arizona, 384 U.S. 436 (1966) (landmark criminal-procedure precedent relied on in stare decisis discussion)
- Gideon v. Wainwright, 372 U.S. 335 (1963) (another core incorporation-era case emphasizing federal rights applied to States)