Ramos v. Louisiana

Ramos v. Louisiana, 590 U.S. ___ (2020), was a U.S. Supreme Court decision in which the Court ruled that the Sixth Amendment to the U.S. Constitution requires that guilty verdicts for criminal trials be unanimous. 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 case Apodaca v. Oregon.[1][2]

Ramos v. Louisiana
Argued October 7, 2019
Decided April 20, 2020
Full case nameEvangelisto Ramos, Petitioner v. Louisiana
Docket no.18–5924
Citations590 U.S. ___ (more)
140 S. Ct. 1390
ArgumentOral argument
Case history
Prior
  • Defendant convicted of second-degree murder based on 10-to-2 jury verdict, sentenced to life in prison without possibility of parole.
  • Affirmed, State v. Ramos, 231 So. 3d 44 (La. Ct. App. 2017); writs denied, 257 So. 3d 679, 253 So. 3d 1300 (La. 2018).
  • Cert. granted, 139 S. Ct. 1318 (2019).
Holding
The Sixth Amendment to the United States Constitution requires that guilty verdicts for criminal trials be unanimous.
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Neil Gorsuch · Brett Kavanaugh
Case opinions
MajorityGorsuch, joined by Ginsburg, Breyer, Sotomayor, Kavanaugh (parts I, II–A, III, IV–B–1); Ginsburg, Breyer, Sotomayor (parts II–B, IV–B–2, V); Ginsburg, Breyer (part IV–A)
ConcurrenceSotomayor (all but part IV–A)
ConcurrenceKavanaugh (in part)
ConcurrenceThomas (in judgment)
DissentAlito, joined by Roberts; Kagan (all but part III–D)
Laws applied
U.S. Const. amends. VI, XIV
This case overturned a previous ruling or rulings
Apodaca v. Oregon

Background

The Sixth Amendment to the United States Constitution defines procedures for prosecution of criminal cases against individuals, parts of which has been incorporated against states by various Supreme Court decisions under the Due Process Clause of the Fourteenth Amendment. The Sixth Amendment assures a jury trial for a person charged on a criminal offense, but does not specify the process around that trial, leaving it for states to define within their own constitutions.[2]

While federal law mandated that a federal jury trial require a unanimous vote to convict a suspect on a criminal charge, the 1972 Supreme Court case Apodaca v. Oregon ruled that states did not have to follow this. All but two states adopted unanimous jury votes to convict. Oregon allowed a jury vote of 10–2 or more for conviction (which Apodaca v. Oregon had challenged), while Louisiana, until 2019, had similarly allowed a 10–2 jury vote to convict, but since had passed a new constitutional amendment requiring a unanimous jury vote, applying to all criminal charges placed on January 1, 2019 or later.[2][3]

The present case's petitioner, Evangelisto Ramos, had been convicted of murder in Louisiana on a 10–2 vote in 2016, before the passage of the new constitutional amendment. Ramos appealed the conviction on the issue around the non-unanimous jury factor, arguing that the law, established in 1898, was a Jim Crow law that allowed for racial discrimination within juries.[2][3][4] The Louisiana Court of Appeal, Fourth Circuit upheld his sentence in a November 2017 opinion.[5]

Ramos petitioned to the U.S. Supreme Court on the question "Whether the Fourteenth Amendment fully incorporates the Sixth Amendment guarantee of a unanimous verdict". The Court accepted the case in March 2019.[6] Oral hearings for the case were held on October 7, 2019.[4]

Decision

The Court issued its decision on April 20, 2020. In a 6–3 decision, the Court reversed the decision against Ramos and ruled that the unanimity of a jury vote for conviction set by the Sixth Amendment must also be an incorporated right against the states, overturning Apodaca v. Oregon.[7] Justice Neil Gorsuch wrote the majority opinion, joined in parts by justices Ruth Bader Ginsburg, Sonia Sotomayor, Stephen Breyer and Brett Kavanaugh, which holds that the guarantee is incorporated by the Due Process Clause of the Fourteenth Amendment. Clarence Thomas joined in the judgment only, arguing instead that it is incorporated by the Privileges or Immunities Clause of the Fourteenth Amendment.[8]

Justice Samuel Alito wrote the dissent joined by Chief Justice John Roberts and Elena Kagan. Alito wrote that the Court should uphold the principle of stare decisis since both Oregon and Louisiana have used the ruling from Apodaca v. Oregon for more than forty years.[2][7]

References
  1. Ramos v. Louisiana, No. 18-5924, 590 U.S. ___ (2020).
  2. de Vogue, Ariana (April 20, 2020). "Supreme Court says unanimous jury verdicts required in state criminal trials for serious offenses". CNN. Retrieved April 20, 2020.
  3. Lopez, German (November 6, 2018). "Louisiana votes to eliminate Jim Crow jury law with Amendment 2". Vox. Retrieved April 20, 2020.
  4. Liptak, Adam (October 7, 2019). "Supreme Court Weighs Ending Non-Unanimous Jury Verdicts in Criminal Cases". The New York Times. Retrieved April 20, 2020.
  5. State v. Ramos, 231 So. 3d 44 (La. Ct. App. 2017).
  6. Barnes, Robert (March 28, 2019). "Supreme Court to examine whether unanimous juries are required for criminal convictions". The Washington Post. Retrieved April 23, 2020.
  7. Rubin, Jordan S. (April 20, 2020). "Supreme Court Bolsters Unanimous Jury Rule in Louisiana Case (3)". Bloomberg Law. Bloomberg Law. Archived from the original on April 28, 2020. Retrieved July 10, 2020.
  8. Volokh, Eugene (April 20, 2020). "Constitution Requires Unanimous Criminal Jury Verdicts for Conviction". Reason. Retrieved April 20, 2020.
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