Edwards v. Vannoy

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Post-Conviction Relief
  • Date Filed: May 17, 2021
  • Case #: 19-5807
  • Judge(s)/Court Below: KAVANAUGH, J., delivered the opinion of the Court, in which ROBERTS, C. J., THOMAS, ALITO, GORSUCH, and BARRETT, JJ., joined. THOMAS, J., filed a concurring opinion, in which GORSUCH, J., joined. GORSUCH, J., filed a concurring opinion, in which THOMAS, J., joined. KAGAN, J., filed a dissenting opinion, in which BREYER and SOTOMAYOR, JJ., joined.
  • Full Text Opinion

New procedural rules announced by the Supreme Court are not retroactively applied on federal collateral review.

Petitioner was convicted of various crimes by a nonunanimous jury.  After Petitioner’s conviction became final in the state courts, he filed a federal petition for habeas corpus, which was rejected by the District Court and the Court of Appeals for the Fifth Circuit.  While his writ of certiorari was pending, the Supreme Court of the United States decided Ramos v. Louisiana, 590 U. S. ___ (2020), which required a unanimous jury verdict to convict a defendant of a serious crime.  Petitioner argued before the Supreme Court that Ramos should be applied retroactively.  On appeal, the Supreme Court affirmed the Fifth Circuit’s ruling, holding that Ramos “does not apply retroactively on federal collateral review.”  The Supreme Court reasoned that Ramos announced “a new rule of criminal procedure” and that this rule was not a “watershed” rule.  Therefore, Ramos does not apply retroactively, because only watershed new rules of criminal procedure qualify for retroactive application.  Teague v. Lane, 489 U. S. 288, 311 (1989) (plurality opinion).  Further, the Court determined that, because no new procedural rule has ever been considered watershed, the watershed exception is moribund; new “procedural rules do not apply retroactively on federal collateral review.”  AFFIRMED.

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