Ramos v. Louisiana
140 S. Ct. 1390
| SCOTUS | 2020Background
- Ramos was convicted by a nonunanimous (10–2) jury in a state felony trial; the Supreme Court granted review to decide the constitutional question about jury unanimity in state prosecutions.
- The Court overruled Apodaca v. Oregon (406 U.S. 404 (1972)) and held that the Sixth Amendment jury-trial right requires unanimous guilty verdicts in state criminal cases.
- The opinions were fractured: a majority abandons Apodaca; Justices filed separate concurrences/dissents debating stare decisis, incorporation, remedy, and retroactivity.
- Key factual context: Louisiana and Oregon long permitted nonunanimous juries; the opinion emphasizes Louisiana’s and Oregon’s historical ties to Jim Crow–era motives for adopting nonunanimity (relevant to the Court’s analysis for overruling).
- Major doctrinal issues addressed: (1) original meaning and precedent on unanimity; (2) stare decisis framework for overruling constitutional precedent; (3) whether Apodaca’s reliance interests and consequences counsel retention; (4) retroactivity on collateral review under Teague.
Issues
| Issue | Plaintiff's Argument (Ramos) | Defendant's Argument (States) | Held |
|---|---|---|---|
| Whether the Sixth Amendment requires unanimous jury verdicts in state felony trials | Sixth Amendment (as originally understood) and incorporation require unanimity; Apodaca was wrongly decided | Apodaca controls; states may lawfully permit nonunanimous verdicts; heavy reliance interests favor retention | Court overruled Apodaca and held the Sixth Amendment requires unanimous guilty verdicts in state felony trials |
| Whether Apodaca should be retained under stare decisis | Apodaca was egregiously wrong, incoherent with precedent, and its racist origins counsel overruling | Stare decisis weighs strongly: Apodaca generated long-standing reliance and large systemic consequences if overturned | A majority concluded special justification existed to overrule Apodaca (disagreement among Justices about aspects of that analysis) |
| Relevance of historical racial motivations for Louisiana/Oregon adoption of nonunanimous rules | Racially discriminatory origins and continuing effects support overruling and undermine legitimacy of the rule | Historical origins are irrelevant to the constitutional question; modern adoptions and neutral motives matter | Several Justices treated the racially discriminatory origins as an important factor favoring overruling; dissent criticized reliance on origins |
| Retroactivity / remedy for past convictions (Teague issue) | New rule applies on direct review; collateral habeas retroactivity governed by Teague exceptions | Overruling will upend many convictions and impose major reliance burdens; Teague may limit collateral relief | The majority did not fully resolve retroactivity; several Justices (Kavanaugh concurring) reasoned Teague bars retroactive habeas relief for final convictions; issue left partly open for future proceedings |
Key Cases Cited
- Apodaca v. Oregon, 406 U.S. 404 (1972) (plurality/concurrence/dissent decision that allowed nonunanimous state convictions and the precedent overruled in this case)
- Duncan v. Louisiana, 391 U.S. 145 (1968) (incorporation of Sixth Amendment jury right against the States)
- Thompson v. Utah, 170 U.S. 343 (1898) (early Supreme Court recognition that jury unanimity was required)
- Patton v. United States, 281 U.S. 276 (1930) (statement that the Sixth Amendment requires unanimous verdicts)
- Marks v. United States, 430 U.S. 188 (1977) (method for identifying holding in fractured decisions)
- Teague v. Lane, 489 U.S. 288 (1989) (framework governing retroactivity of new rules in federal habeas corpus)
- Williams v. Florida, 399 U.S. 78 (1970) (analysis on which Apodaca built regarding which common-law jury features are incorporated)
- Ring v. Arizona, 536 U.S. 584 (2002) (example of overruling precedent to correct serious criminal-procedure errors)
- Batson v. Kentucky, 476 U.S. 79 (1986) (addressing race discrimination in jury selection; analogized for effects of nonunanimous rules)
- Brown v. Board of Education, 347 U.S. 483 (1954) (canonical example of overruling precedent for grave constitutional error)