Edwards v. Vannoy rewrites
The Supreme Court this morning handed down an opinion in
Edwards v. Vannoy, No. 19–5807 (S. Ct. May 17, 2021) (available here), which holds that the "
Ramos jury-unanimity rule ... does not apply retroactively on federal collateral review." Justice Kavanaugh wrote the opinion for the Court, and it starts this way:
Last Term in
Ramos v. Louisiana, 590 U. S. ___ (2020), this Court held that a state jury must be unanimous to convict a criminal defendant of a serious offense.
Ramos repudiated this Court’s 1972 decision in
Apodaca v. Oregon, 406 U.S. 404, which had allowed non-unanimous juries in state criminal trials. The question in this case is whether the new rule of criminal procedure announced in