Summary
In *Edwards v. Vannoy*, the Supreme Court held that the new rule announced in *Ramos v. Louisiana*—requiring unanimous jury verdicts in state criminal trials—does not apply retroactively on federal collateral review. The Court reaffirmed that new procedural rules generally do not apply retroactively under *Teague v. Lane*, and declared the "watershed" exception moribund, as no new procedural rule has ever satisfied it. The decision emphasizes finality of convictions and the limits of habeas corpus relief, rejecting arguments based on the rule's importance, original meaning, or anti-discrimination purpose.
Topics
Practice areas
Questions Presented
- Whether the new rule of criminal procedure announced in Ramos v. Louisiana, requiring jury unanimity in state criminal trials, applies retroactively on federal collateral review.
Holdings
- The Ramos jury-unanimity rule does not apply retroactively on federal collateral review. New procedural rules do not apply retroactively on federal collateral review, and the watershed exception is moribund.
Key quotations
“New procedural rules do not apply retroactively on federal collateral review.” (at 15)
“The watershed exception is moribund. It must be regarded as retaining no vitality.” (at 15)
Factual background
In 2006, Thedrick Edwards and an accomplice kidnapped a student at gunpoint, robbed him, and later raped two women. Edwards was convicted by a Louisiana jury with 11-1 and 10-2 votes, as permitted by Louisiana law at the time. He was sentenced to life imprisonment without parole. His conviction became final on direct review in 2011.
Procedural history
Edwards was convicted by a non-unanimous jury in Louisiana. He sought federal habeas corpus, arguing that the non-unanimous verdict violated his constitutional right to a unanimous jury. The District Court rejected the claim as foreclosed by Apodaca v. Oregon, 406 U.S. 404 (1972), and the Fifth Circuit denied a certificate of appealability. While his certiorari petition was pending, this Court decided Ramos v. Louisiana, 590 U.S. ___ (2020), which held that the Sixth Amendment requires a unanimous jury in state criminal trials. The Court granted certiorari to decide whether Ramos applies retroactively on federal collateral review.