Edwards v. Vannoy | |
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Argued December 2, 2020 Decided May 17, 2021 | |
Full case name | Thedrick Edwards v. Darrel Vannoy, Warden |
Docket no. | 19-5807 |
Citations | 593 U.S. 255 ( more ) 141 S. Ct. 1547 209 L. Ed. 2d 651 |
Case history | |
Prior |
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Holding | |
The Ramos jury-unanimity rule does not apply retroactively on federal collateral review. | |
Court membership | |
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Case opinions | |
Majority | Kavanaugh, joined by Roberts, Thomas, Alito, Gorsuch, Barrett |
Concurrence | Thomas, joined by Gorsuch |
Concurrence | Gorsuch, joined by Thomas |
Dissent | Kagan, joined by Breyer, Sotomayor |
This case overturned a previous ruling or rulings | |
Teague v. Lane (1989) (in part) |
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.
Under the Sixth Amendment to the U.S. Constitution, a person accused of criminal charges must be tried by a jury. Federal laws required the jury to come to a unanimous decision to achieve conviction, but states had been free to adapt their own requirements for conviction based on the 1972 case Apodaca v. Oregon . Only Louisiana and Oregon allowed non-unanimous convictions. [1]
A fractured court overturned Apodaca in Ramos v. Louisiana , deciding that the Sixth Amendment right to a unanimous jury verdict applied to the states, at least for felony convictions. [2] [3] Six justices agreed that Apodaca should be overturned but did not decide whether the decision would apply retroactively to cases on federal collateral review. [4]
Thedrick Edwards and an accomplice kidnapped LSU student Ryan Eaton at gunpoint in Baton Rogue, Louisiana on May 13 2006. They drove to an ATM but Eaton had no money in his accounts. They decided to go to his apartment where they blindfolded him, tied his hands and stole some of his personal belongings. Back in the car, they made Eaton arrange a meeting with his girlfriend. They went to her apartment and forced Eaton to knock on the door at gunpoint. When she opened the door the assailants rushed into the apartment. Eaton's girlfriend was there with her friend and roommate. Two of the women were raped. Two days later a pair of men forced their way into another man's car at gunpoint, drove to an ATM and robbed him. Police obtained a warrant to search Edward's residence and arrest him. Edwards turned himself in after police executed the search warrant. His confession was videotaped. [5]
Edwards was convicted in 2007 in Louisiana on charges of rape, armed robbery, and kidnapping. Edwards is black and the victims were white college students. The jury was 10–2 on some counts and 11–1 on others. The only black juror voted to acquit on all charges. Adam Liptak noted that prosecutors used 10 of 11 peremptory challenges to strike black jurors. [6] [7] [8]
After Edwards's conviction became final in March 2011 he filed for federal habeas relief based on his constitutional right to a unanimous jury. His petition was denied based on Apodaca. The Fifth Circuit Court of Appeals agreed with the District Court. [9]
Edwards filed a petition for certiorari at the United States Supreme Court before Ramos was decided. [9] He subsequently changed his petition to the Court to ask whether the Ramos decision should apply retroactively. The Court granted certiorari to Edwards' revised petition in May 2020 on the limited question of whether Ramos v. Louisiana applied retroactively to cases on federal collateral review. [10] [11]
Oral arguments were heard on December 2, 2020 via teleconference due to the ongoing COVID-19 pandemic. The Louisiana Solicitor General argued that retroactive application of Ramos would require re-trial for thousands of cases "that involve terrible crimes" and would be unfair to the victims. Edwards attorney argued that the case fell within the watershed exception to the Teague doctrine that otherwise foreclosed retroactive applicability of new procedural rules on federal collateral review. The Court has never recognized a "watershed" rule under the Teague doctrine. The right to an attorney established by Gideon v. Wainwright is generally accepted to be a watershed rule but that case was decided before Teague. The defense argued that the Ramos unanimity rule should fall within the "watershed rule" exception because it was comparable to Gideon. [12]
The Court issued its decision on May 17, 2021. In a 6–3 ruling, the Court affirmed the lower court's ruling. The majority opinion was written by Justice Brett Kavanaugh.
Most Supreme Court decisions on new rules of criminal procedure do not have retroactive applicability for finalized convictions on federal collateral review. This 1989 decision Teague v. Lane created an exception for "watershed rules" but the Supreme Court has never applied any procedural rule retroactively under the exception. Justice Kavanaugh wrote for the conservative majority: [13]
It is time—probably long past time—to make explicit what has become increasingly apparent to bench and bar over the last 32 years: New procedural rules do not apply retroactively on federal collateral review. The watershed exception is moribund.
Kavanaugh said the watershed exception was "theoretical" acknowledging that it "never actually applies in practice":
Continuing to articulate a theoretical exception that never actually applies in practice offers false hope to defendants, distorts the law, misleads judges, and wastes the resources of defense counsel, prosecutors, and courts.
In the opinion, Kavanaugh also suggested that it would be impossible for any future change in criminal court proceedings to satisfy the "watershed" exception defined in the Teague ruling. As such, Kavanaugh considered that that portion of the Teague ruling was overturned: [14]
If landmark and historic criminal procedure decisions—including Mapp, Miranda, Duncan, Crawford, Batson, and now Ramos—do not apply retroactively on federal collateral review, how can any additional new rules of criminal procedure apply retroactively on federal collateral review? At this point, some 32 years after Teague, we think the only candid answer is that none can—that is, no new rules of criminal procedure can satisfy the watershed exception. We cannot responsibly continue to suggest otherwise to litigants and courts.
Justice Elena Kagan wrote the dissenting opinion joined by Justices Stephen Breyer and Sonia Sotomayor. Kagan wrote that "those convicted under rules found not to produce fair and reliable verdicts will be left without recourse in federal courts." [15]
Kagan remarked: "If you were scanning the thesaurus for a single word to describe the [Ramos] decision you would stop when you came to watershed." [13]
While the Supreme Court opted to not consider the Ramos decision to be retroactive, the Oregon Supreme Court ruled in December 2022 that the Ramos decision should be applied retroactively to cases within the state. [16]
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.
Schriro v. Summerlin, 542 U.S. 348 (2004), was a case in which the United States Supreme Court held that a requirement that a different Supreme Court decision requiring the jury rather than the judge to find aggravating factors would not be applied retroactively.
Whorton v. Bockting, 549 U.S. 406 (2007), was a United States Supreme Court case about the application of the Confrontation Clause and whether Crawford v. Washington (2006) applied retroactively. Justice Samuel Alito, writing for a unanimous Court, ruled that Crawford did not apply retroactively.
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.
United States criminal procedure derives from several sources of law: the baseline protections of the United States Constitution; federal and state statutes; federal and state rules of criminal procedure ; and state and federal case law. Criminal procedures are distinct from civil procedures in the US.
United States v. Johnson, 457 U.S. 537 (1982), was a United States Supreme Court case.
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.
The United States Constitution contains several provisions regarding the law of criminal procedure.
Montgomery v. Louisiana, 577 U.S. 190 (2016), was a United States Supreme Court case in which the Court held that its previous ruling in Miller v. Alabama (2012), that a mandatory life sentence without parole should not apply to persons convicted of murder committed as juveniles, should be applied retroactively. This decision potentially affects up to 2,300 cases nationwide.
Flowers v. Mississippi, No. 17–9572, 588 U.S. 284 (2019), is a United States Supreme Court decision regarding the use of peremptory challenges to remove black jurors during a series of Mississippi criminal trials for Curtis Flowers, a black man convicted on murder charges. The Supreme Court held in Batson v. Kentucky that the use of peremptory challenges solely on the basis of race is unconstitutional. This case examined whether the Mississippi Supreme Court erred in how it applied Batson to this case. The Supreme Court ruled that Flowers' case fell under Batson and that the state inappropriately removed most of the potential black jurors during the trials.
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.
Tyler v. Cain, 533 U.S. 656 (2001) is a United States Supreme Court case in which the Court held that the rule established under Cage v. Louisiana (1990), where the Court held certain jury instructions unconstitutional because the words used did not suggest the degree of proof required by the "beyond a reasonable doubt" standard, was not "made retroactive to cases on collateral review by the Supreme Court." Tyler is the primary case regarding the retroactivity of new rules to successive habeas petitions.
Oklahoma v. Castro-Huerta, 597 U.S. 629 (2022), was a United States Supreme Court case related to McGirt v. Oklahoma, decided in 2020. In McGirt, the Supreme Court ruled that the U.S. Congress never properly disestablished the Indian reservations of the Five Civilized Tribes in Oklahoma when granting its statehood, and thus almost half the state was still considered to be Native American land. As a result of McGirt, crimes under the Major Crimes Act by Native Americans in the reservations are treated as federal crimes rather than state crimes.
Wooden v. United States, 595 U.S. ___ (2022), was a Supreme Court of the United States case dealing with the Armed Career Criminal Act (ACCA). In a unanimous decision, the court ruled that multiple criminal offenses that a person commits during a single criminal episode do not count as separate convictions when considering the number of prior convictions a criminal has under the ACCA.
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.