Ramos v. Louisiana

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Constitutional Law
  • Date Filed: April 20, 2020
  • Case #: 18-5924
  • Judge(s)/Court Below: GORSUCH, J., announced the judgment of the Court, and delivered the opinion of the Court with respect to Parts I, II–A, III, and IV–B–1, in which GINSBURG, BREYER, SOTOMAYOR, and KAVANAUGH, JJ., joined, an opinion with respect to Parts II–B, IV–B–2, and V, in which GINSBURG, BREYER, and SOTOMAYOR, JJ., joined, and an opinion with respect to Part IV–A, in which GINSBURG and BREYER, JJ., joined. SOTOMAYOR, J., filed an opinion concurring as to all but Part IV–A. KAVANAUGH, J., filed an opinion concurring in part. THOMAS, J., filed an opinion concurring in the judgment. ALITO, J., filed a dissenting opinion, in which ROBERTS, C. J., joined, and in which KAGAN, J., joined as to all but Part III–D.
  • Full Text Opinion

The Sixth Amendment’s protection against nonunanimous felony guilty verdicts applies to States through the Fourteenth Amendment’s Due Process Clause. Duncan v. Louisiana, 391 U. S. 145 (1968)

Louisiana charged Petitioner with second-degree murder. Petitioner invoked his right to a jury trial and ten jurors found the government had proven its case, but two jurors found that the government failed to prove Petitioner’s guilt beyond a reasonable doubt. Under Louisiana’s non-unanimous jury verdict law, the lower court sentenced Petitioner to life in prison without the possibility of parole. The court of appeals affirmed, concluding that non-unanimous jury verdicts do not violate the U.S. Constitution, and the Louisiana Supreme Court denied review. On further review, the U.S. Supreme Court reversed the judgment, holding that Petitioner’s conviction by a nonunanimous jury constituted an unconstitutional denial of the Sixth Amendment right to a jury trial. The Court reasoned that the Sixth Amendment’s term “trial by an impartial jury” entails a requirement of unanimity, which the Court traced back to the common law of 14th century England. The Court also addressed two of its decisions justifying non-unanimous jury verdicts and concluded that the doctrine of stare decisis did not justify preserving such precedent, because the two cases at issue improperly subjected the guarantee of a unanimous jury verdict to a functionalist assessment and constituted clearly mistaken outliers where the Supreme Court has stated multiple times over 120 years that the Sixth Amendment requires unanimity. REVERSED.

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