| Andres v. United States | |
|---|---|
 | |
| Decided April 26, 1948 | |
| Full case name | Andres v. United States |
| Citations | 333 U.S. 740 ( more ) |
| Holding | |
| Jury verdicts must be unanimous for federal prosecutions. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Reed, joined by unanimous |
| Laws applied | |
| U.S. Const. amend. VI | |
Andres v. United States, 333 U.S. 740 (1948), was a United States Supreme Court case in which the Court held that jury verdicts must be unanimous for federal prosecutions. [1] [2]
A jury trial, or trial by jury, is a legal proceeding in which a jury makes a decision or findings of fact. It is distinguished from a bench trial, in which a judge or panel of judges makes all decisions.
The Sixth Amendment to the United States Constitution sets forth rights related to criminal prosecutions. It was ratified in 1791 as part of the United States Bill of Rights. The Supreme Court has applied all but one of this amendment's protections to the states through the Due Process Clause of the Fourteenth Amendment.
A hung jury, also called a deadlocked jury, is a judicial jury that cannot agree upon a verdict after extended deliberation and is unable to reach the required unanimity or supermajority. A hung jury may result in the case being tried again.
Batson v. Kentucky, 476 U.S. 79 (1986), was a landmark decision of the United States Supreme Court ruling that a prosecutor's use of a peremptory challenge in a criminal case—the dismissal of jurors without stating a valid cause for doing so—may not be used to exclude jurors based solely on their race. The Court ruled that this practice violated the Equal Protection Clause of the Fourteenth Amendment. The case gave rise to the term Batson challenge, an objection to a peremptory challenge based on the standard established by the Supreme Court's decision in this case. Subsequent jurisprudence has resulted in the extension of Batson to civil cases and cases where jurors are excluded on the basis of sex.
Unanimity is agreement by all people in a given situation. Groups may consider unanimous decisions as a sign of social, political or procedural agreement, solidarity, and unity. Unanimity may be assumed explicitly after a unanimous vote or implicitly by a lack of objections. It does not necessarily mean uniformity and can sometimes be the opposite of majority in terms of outcomes.
In United States constitutional law, incorporation is the doctrine by which portions of the Bill of Rights have been made applicable to the states. When the Bill of Rights was ratified, the courts held that its protections extended only to the actions of the federal government and that the Bill of Rights did not place limitations on the authority of the state and local governments. However, the post–Civil War era, beginning in 1865 with the Thirteenth Amendment, which declared the abolition of slavery, gave rise to the incorporation of other amendments, applying more rights to the states and people over time. Gradually, various portions of the Bill of Rights have been held to be applicable to state and local governments by incorporation via the Due Process Clause of the Fourteenth Amendment of 1868.
Hernandez v. Texas, 347 U.S. 475 (1954), was a landmark case, "the first and only Mexican-American civil-rights case heard and decided by the United States Supreme Court during the post-World War II period." In a unanimous ruling, the court held that Mexican Americans and all other nationality groups in the United States have equal protection under the 14th Amendment of the U.S. Constitution. The ruling was written by Chief Justice Earl Warren. This was the first case in which Mexican-American lawyers had appeared before the Supreme Court.
Rice v. Collins, 546 U.S. 333 (2006), was a decision by the Supreme Court of the United States regarding a prosecutor's use of a peremptory challenge to remove a young African American woman, Juror 16, from a defendant's drug trial jury in a California court case, based on her youth and on her alleged "eye rolling" in answer to a question. The defendant, Steven Martell Collins, challenged the striking of Juror 16, saying her exclusion was based on race, but the trial judge agreed that the prosecutor's reasons were race-neutral. The California Court of Appeal upheld the trial court's ruling, and the Federal District Court dismissed Collins' habeas corpus petition with prejudice. However, the Ninth Circuit Court of Appeals reversed and remanded, stating that the dismissal was unreasonable based, among other reasons, on the lack of evidence that the eye rolling had occurred.
Apodaca v. Oregon, 406 U.S. 404 (1972), was a United States Supreme Court case in which the Court held that state juries may convict a defendant by a less-than-unanimous verdict in a felony criminal case. The four-justice plurality opinion of the court, written by Justice White, affirmed the judgment of the Oregon Court of Appeals and held that there was no constitutional right to a unanimous verdict. Although federal law requires federal juries to reach criminal verdicts unanimously, the Court held Oregon's practice did not violate the Sixth Amendment right to trial by jury and so allowed it to continue. In Johnson v. Louisiana, a case decided on the same day, the Court held that Louisiana's similar practice of allowing criminal convictions by a jury vote of 9–3 did not violate due process or equal protection under the Fourteenth Amendment.
A citizen's right to a trial by jury is a central feature of the United States Constitution. It is considered a fundamental principle of the American legal system.
Johnson v. United States, 529 U.S. 694 (2000), was a United States Supreme Court case in which the rights of those serving federal probation and supervised release were more clearly defined. The court ruled that "Although such violations often lead to reimprisonment, the violative conduct need not be criminal and need only be found by a judge under a preponderance of the evidence standard, not by a jury beyond a reasonable doubt."
The United States Constitution contains several provisions regarding the law of criminal procedure.
Warger v. Shauers, 574 U.S. 40 (2014), was a unanimous decision by the United States Supreme Court, ruling that jurors may not testify about what occurred during jury deliberations, even to expose dishonesty during jury selection or voir dire. The Court delivered its ruling on December 9, 2014.
In re Oliver, 333 U.S. 257 (1948), was a decision by the United States Supreme Court involving the application of the right of due process in state court proceedings. The Sixth Amendment in the Bill of Rights states that criminal prosecutions require the defendant "... to be informed of the nature and cause of the accusation...and to have the Assistance of Counsel for his defence." In this case, a witness in a Michigan grand jury hearing was convicted and sentenced to jail without either notice or attorney assistance.
Blueford v. Arkansas, 566 U.S. 599 (2012), was a decision of the Supreme Court of the United States that clarified the limits of the Double Jeopardy Clause. The Supreme Court held that the Double Jeopardy Clause does not bar retrial of counts that a jury had previously unanimously voted to acquit on, when a mistrial is declared after the jury deadlocked on a lesser included offense.
Ramos v. Louisiana, 590 U.S. 83 (2020), is 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 criminal trials. See 590 U.S. 83 at 90 (2020) "Wherever we might look to determine what the term “trial by an impartial jury” meant at the time of the Sixth Amendment's adoption—whether it's the common law, state practices in the founding era, or opinions and treatises written soon afterward—the answer is unmistakable. A jury must reach a unanimous verdict in order to convict." 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 and Johnson v. Louisiana.
Johnson v. United States, 333 U.S. 10 (1948), was a significant United States Supreme Court decision addressing search warrants and the Fourth Amendment. In this case, where federal agents had probable cause to search a hotel room but did not obtain a warrant, the Court declared the search was "unreasonable."
Edwards v. Vannoy, 593 U.S. ___ (2021), was a United States Supreme Court case involving the Court's prior decision in Ramos v. Louisiana, 590 U.S. ___ (2020), which had ruled that jury verdicts in criminal trials must be unanimous under the Sixth Amendment to the U.S. Constitution. The Supreme Court ruled 6–3 that Ramos did not apply retroactively to earlier cases prior to their verdict in Ramos.
Johnson v. Louisiana, 406 U. S. 356 (1972), was a court case in the U.S. Supreme Court involving the Due Process Clause and Equal Protection Clause of the Fourteenth Amendment to the United States Constitution. The U.S. Supreme Court ruled that the Louisiana law that allowed less-than unanimous jury verdicts to convict persons charged with a felony, does not violate the Due Process clause. This case was argued on a similar basis as Apodaca v. Oregon.
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