334 So.3d 844
La. Ct. App.2022Background
- Stanley Waldron was convicted in 2000 of attempted second-degree murder by an 11–1 jury verdict and sentenced to 50 years at hard labor.
- In April 2021 Waldron filed a post-conviction application arguing his non‑unanimous conviction violates the Sixth Amendment under Ramos v. Louisiana (2020).
- The St. Bernard Parish district court denied relief after a June 15, 2021 hearing and Waldron sought supervisory review in the Louisiana Fourth Circuit.
- The Fourth Circuit reviewed Ramos, Edwards v. Vannoy, Louisiana legislative history, and state retroactivity doctrine (Taylor) and found Ramos controls the constitutional question.
- The court concluded Louisiana’s non‑unanimous verdict rule has racially discriminatory origins and materially undermined accuracy and fairness, and therefore Ramos must be applied retroactively in state collateral proceedings.
- The Fourth Circuit granted the writ, reversed the district court, and granted Waldron post‑conviction relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an 11–1 jury verdict violates the Sixth Amendment | Waldron: non‑unanimous verdicts violate the Sixth Amendment per Ramos | State: historically upheld non‑unanimous verdicts; finality concerns | Held: Ramos controls; non‑unanimous verdicts are unconstitutional |
| Whether Ramos applies retroactively on Louisiana state collateral review | Waldron: Ramos announces a new rule and is retroactively applicable; timely filed under La. C.Cr.P. art. 930.8 | State: Edwards limits Ramos retroactivity on federal collateral review and finality/federalism concerns | Held: Edwards does not bind states; Louisiana courts may and here do apply Ramos retroactively |
| Whether Ramos qualifies as a "watershed" rule under Teague/Taylor | Waldron: Ramos is watershed in LA because of racially discriminatory origin and effect on accuracy/fairness | State: Teague watershed exception is moribund and should not apply to Ramos | Held: Under Louisiana's history and Taylor, the court treats Ramos as watershed and retroactive |
| Timeliness of post‑conviction filing under La. C.Cr.P. art. 930.8 | Waldron: filed within one year of Ramos finality; thus timely | State: (implicit) challenges based on finality and collateral‑review limits | Held: Court accepts timeliness and considers the claim on the merits |
Key Cases Cited
- Ramos v. Louisiana, 140 S.Ct. 1390 (U.S. 2020) (held non‑unanimous jury verdicts unconstitutional under the Sixth Amendment)
- Edwards v. Vannoy, 141 S.Ct. 1547 (U.S. 2021) (held Ramos does not apply retroactively on federal collateral review; states may choose different rules)
- Teague v. Lane, 489 U.S. 288 (U.S. 1989) (framework for retroactivity of new rules on collateral review)
- Danforth v. Minnesota, 552 U.S. 264 (U.S. 2008) (states free to give broader retroactive effect than federal habeas retroactivity rules)
- State ex rel. Taylor v. Whitley, 606 So.2d 1292 (La. 1992) (Louisiana adopted Teague standards for state collateral review)
- State v. Bertrand, 6 So.3d 738 (La. 2009) (prior Louisiana precedent upholding non‑unanimous verdicts)
- Apodaca v. Oregon, 406 U.S. 404 (U.S. 1972) (plurality decision previously interpreted to permit non‑unanimous state verdicts)
- Gideon v. Wainwright, 372 U.S. 335 (U.S. 1963) (example of the one pre‑Teague rule treated as watershed)
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (contextual precedent discussed in retroactivity analysis)
- Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (contextual precedent discussed in retroactivity analysis)