Key Takeaways

1. The Supreme Court in Ramos v. Louisiana (2020) held that the Sixth Amendment requires unanimous jury verdicts in state criminal trials, overturning prior precedent and invalidating non-unanimous verdicts in Louisiana and Oregon.
2. The decision has profound implications for the criminal justice system, especially regarding the fairness of trials and the historical context of racial discrimination in jury verdicts.
3. Ramos does not apply retroactively to cases that were already final before the decision, limiting its impact on past convictions but setting a new standard for future cases.

Introduction

Ramos v. Louisiana, 590 U.S. ___ (2020), is a landmark Supreme Court case that fundamentally reshaped the landscape of criminal jury trials in the United States. Decided on April 20, 2020, the case addressed whether the Sixth Amendment’s guarantee of a unanimous jury verdict in criminal cases applies to state courts via the Fourteenth Amendment. This decision overturned longstanding precedent and had immediate and far-reaching consequences for criminal defendants, courts, and the broader justice system.

This guide provides a comprehensive overview of Ramos v. Louisiana, including its background, legal arguments, Supreme Court decision, dissenting opinions, subsequent developments, and ongoing significance. We aim to clarify the case’s complexities and highlight why it remains a pivotal moment in American constitutional law.

Background of Ramos v. Louisiana

The Facts of the Case

The case began when Evangelisto Ramos was charged with second-degree murder in Louisiana. Ramos maintained his innocence and opted for a jury trial. After deliberation, the jury convicted him by a 10-2 vote, rather than a unanimous verdict. Under Louisiana law at the time, such non-unanimous verdicts were sufficient for conviction in felony cases.

Ramos was sentenced to life imprisonment without the possibility of parole. He appealed, arguing that his conviction by a non-unanimous jury violated his Sixth Amendment rights as applied to the states through the Fourteenth Amendment. Both the state appellate court and the Louisiana Supreme Court rejected his arguments, prompting review by the U.S. Supreme Court (Oyez case summary).

Historical Context: Non-Unanimous Jury Verdicts

Non-unanimous jury verdicts in criminal trials were historically rare in the United States. Most states required unanimity, but Louisiana and Oregon were exceptions. Louisiana’s law allowing non-unanimous verdicts dated back to the late 19th and early 20th centuries, with roots in efforts to marginalize Black jurors and dilute their influence (Constitutional Accountability Center). Oregon adopted a similar rule in 1934, also amid concerns about minority influence on juries.

The Supreme Court had previously addressed the issue in Apodaca v. Oregon, 406 U.S. 404 (1972), where a divided Court upheld non-unanimous verdicts in state courts. This precedent stood for nearly half a century, despite ongoing criticism of its reasoning and fairness.

Legal Issues Presented

The Sixth Amendment and Jury Unanimity

The Sixth Amendment guarantees the right to a speedy and public trial, by an impartial jury, in all criminal prosecutions. The question before the Court was whether this right to a jury trial includes a requirement that the jury’s verdict be unanimous, and if so, whether that requirement applies to state courts.

Incorporation Through the Fourteenth Amendment

The Fourteenth Amendment's Due Process Clause has long been interpreted to "incorporate" most of the Bill of Rights, making them applicable to the states. However, the Supreme Court had not previously clarified whether the unanimity requirement was incorporated alongside the right to a jury trial.

Challenging Precedent: Apodaca v. Oregon

Ramos’s case squarely challenged the precedent set by Apodaca v. Oregon, which had allowed non-unanimous verdicts in state courts. The Supreme Court had to decide whether to adhere to or overturn this precedent, considering principles of stare decisis (respect for prior decisions).

The Supreme Court’s Decision

The Majority Opinion

In a 6-3 decision, the Supreme Court ruled in favor of Ramos. Justice Neil Gorsuch authored the majority opinion, joined by Justices Ginsburg, Breyer, Sotomayor, and Kavanaugh (Official opinion PDF). The Court held that the Sixth Amendment requires unanimous jury verdicts for convictions in criminal cases, and that this requirement applies to the states through the Fourteenth Amendment.

Justice Gorsuch emphasized the historical understanding of the right to a jury trial, noting that unanimity was a core feature of the jury as it existed at the time of the Founding. He criticized the fractured and confusing reasoning of Apodaca, stating that the Court could not “ignore the truth” of the Sixth Amendment’s guarantee.

Overruling Apodaca v. Oregon

The majority found that Apodaca was inconsistent with the Court’s incorporation jurisprudence. The opinion described Apodaca as a “badly fractured decision” that failed to provide a clear rule and had been widely criticized for its lack of coherent reasoning.

The Court concluded that stare decisis did not justify retaining a precedent that was so clearly at odds with constitutional text and history. As a result, Apodaca v. Oregon was overruled, and non-unanimous jury verdicts in state criminal trials were declared unconstitutional.

Concurrences

Justice Sonia Sotomayor wrote a concurring opinion, emphasizing the racial and historical context of non-unanimous jury laws, particularly in Louisiana. She highlighted how these laws were rooted in efforts to marginalize Black jurors and perpetuate racial discrimination in the justice system.

Justice Brett Kavanaugh also concurred, discussing the doctrine of stare decisis and explaining why he believed it was appropriate to overturn Apodaca. He outlined factors such as the quality of the precedent’s reasoning, its consistency with related decisions, and the practical consequences of maintaining it.

The Dissent

Justice Samuel Alito wrote the principal dissent, joined by Chief Justice John Roberts and, for the most part, Justice Elena Kagan. The dissenters argued that overturning Apodaca was unnecessary and would cause significant disruption. They expressed concern about the retroactive application of the new rule, warning that it could lead to a flood of appeals and retrials, undermining the stability of criminal convictions (Supreme Court opinion).

Immediate Impact and Legal Consequences

Effect on Louisiana and Oregon

At the time of the Ramos decision, Louisiana and Oregon were the only states that permitted non-unanimous jury verdicts in felony cases. The Supreme Court’s ruling immediately invalidated these practices. Louisiana had already voted to eliminate non-unanimous jury convictions for felony cases after 2019, but the Ramos decision made clear that all future convictions required unanimity (Harvard Law Review analysis).

Oregon, which had retained the practice, was also required to change its laws to comply with the ruling. The decision brought both states in line with the rest of the country and reaffirmed the importance of jury unanimity as a safeguard for defendants.

Broader Implications for Criminal Justice

The Ramos decision was widely celebrated by civil rights advocates and legal scholars. It was seen as a victory for defendants’ rights, fairness, and the integrity of the criminal justice system. The case also drew attention to the racially discriminatory origins of non-unanimous jury laws.

The American Civil Liberties Union (ACLU) and other organizations filed amicus briefs in support of Ramos, arguing that non-unanimous verdicts undermined the legitimacy of the justice system and disproportionately harmed minority defendants (ACLU brief).

The Question of Retroactivity

Edwards v. Vannoy: The Limits of Ramos

A crucial question following Ramos was whether its rule should apply retroactively to cases that had already become final before the decision. In Edwards v. Vannoy, 593 U.S. ___ (2021), the Supreme Court addressed this issue. In a 6-3 decision, the Court held that Ramos does not apply retroactively to cases on federal collateral review (NCSC summary).

This meant that only defendants whose convictions were not yet final at the time of the Ramos decision could benefit from the new rule. The majority reasoned that the unanimity requirement was a new procedural rule, not a “watershed” rule of criminal procedure that would justify retroactive application.

Practical Consequences

As a result, the number of cases directly affected by Ramos was limited. Many defendants convicted by non-unanimous juries prior to the decision could not automatically seek new trials. However, the ruling set a clear standard for all future cases, ensuring that non-unanimous jury convictions would no longer occur in state courts.

Legal and Social Significance

Racial Justice and the Jury System

Ramos v. Louisiana is significant not only for its legal reasoning but also for its acknowledgment of the racial injustices embedded in the history of jury laws. As discussed in the opinions and in amicus briefs, non-unanimous jury rules were often adopted to weaken the influence of minority jurors and facilitate convictions of Black defendants.

By requiring unanimity, the Supreme Court reaffirmed the importance of the jury as a democratic institution that reflects community values and guards against government overreach. The decision has been hailed as a step toward greater fairness and equality in the criminal justice system.

The Role of Stare Decisis

Ramos also illustrates the Supreme Court’s approach to stare decisis—the principle that courts should generally adhere to prior decisions. The majority opinion in Ramos demonstrates that the Court is willing to overturn precedent when it is clearly inconsistent with constitutional text and history, particularly where the precedent is poorly reasoned and widely criticized.

This aspect of Ramos has implications for future cases, as it signals the Court’s willingness to revisit and, if necessary, overturn past decisions that are deemed unworkable or unjust.

Scholarly and Judicial Reactions

Legal scholars and commentators have extensively analyzed Ramos v. Louisiana. The decision has been praised for correcting a long-standing injustice and bringing state practices in line with constitutional guarantees. At the same time, some have expressed concern about the challenges of implementing the new rule and the fate of those previously convicted by non-unanimous juries.

The case continues to generate discussion in academic and legal circles, with ongoing debates about the scope of its reasoning and its place in the Court’s broader jurisprudence.

Continuing Developments and Ongoing Questions

State-Level Responses

Following Ramos, both Louisiana and Oregon undertook legislative and judicial efforts to comply with the Supreme Court’s mandate. Louisiana amended its laws to require jury unanimity in felony cases, and Oregon followed suit. State courts have addressed the question of how to handle cases pending at the time of the Ramos decision and whether any exceptions should be made for older cases.

The Broader Legacy

Ramos v. Louisiana stands as a reminder of the evolving nature of constitutional law and the importance of vigilance in protecting individual rights. The case highlights the enduring relevance of the Bill of Rights and the role of the Supreme Court in interpreting and enforcing its guarantees.

By reaffirming the right to a unanimous jury, the Court reinforced the principle that criminal convictions should rest on the considered judgment of the entire community, not a divided jury.

Conclusion

Ramos v. Louisiana is a landmark decision that reshaped the American criminal justice system by requiring unanimous jury verdicts in state criminal trials. The Supreme Court’s ruling overruled decades of precedent and addressed the historical injustices associated with non-unanimous jury laws. While the decision’s retroactive reach is limited, its impact on future cases is profound.

For attorneys, scholars, and anyone interested in constitutional law, Ramos serves as a critical case study in the evolution of the right to a jury trial, the doctrine of stare decisis, and the ongoing struggle for racial justice in the courts.

For further legal research and in-depth analysis, visit Counsel Stack.

Additional Resources

• Ramos v. Louisiana Supreme Court Opinion (PDF)
• Oyez Case Summary: Ramos v. Louisiana
• Harvard Law Review Analysis
• ACLU Amicus Brief
• Constitutional Accountability Center Case Page
• NCSC Newsroom: Retroactivity of Ramos

Disclaimer: This guide is intended for informational purposes only and does not constitute legal advice. Ramos v. Louisiana is a complex case with many nuances, and the application of its principles may vary depending on specific circumstances. For legal advice or representation, consult a qualified attorney.