Edwards v. Vannoy

In 2007, a Louisiana jury convicted Thedrick Edwards of armed robbery, rape, and kidnapping. Louisiana law at the time permitted non-unanimous verdicts if at least 10 of 12 jurors agreed; 11 jurors voted to convict on some counts and 10 on others. After his conviction became final, Edwards filed a federal habeas corpus petition. While his petition was pending, the Supreme Court decided Ramos v. Louisiana (2020), holding that the Sixth Amendment requires unanimous jury verdicts in state criminal trials. Edwards then argued that the Ramos rule should apply retroactively to his case on federal collateral review. In a 6-3 decision authored by Justice Kavanaugh, the Court held that the Ramos jury-unanimity rule does not apply retroactively and declared the "watershed" exception to the non-retroactivity doctrine effectively dead.

The Supreme Court affirmed the judgment of the Fifth Circuit in a 6-3 decision. The Court held that the Ramos jury-unanimity rule does not apply retroactively on federal collateral review. It further declared the "watershed" exception to Teague v. Lane moribund, stating that no new procedural rule is likely to satisfy it. Justice Kavanaugh delivered the majority opinion, joined by Chief Justice Roberts and Justices Thomas, Alito, Gorsuch, and Barrett. Justice Thomas filed a concurring opinion joined by Justice Gorsuch. Justice Kagan filed a dissenting opinion, joined by Justices Breyer and Sotomayor.

Whether the jury-unanimity rule announced in Ramos v. Louisiana (2020) applies retroactively to cases on federal collateral review, and whether the "watershed" exception to the general rule of non-retroactivity remains viable.

The decision left over 1,500 incarcerated individuals in Louisiana (and hundreds in Oregon) convicted by non-unanimous juries without federal recourse, approximately 80% of whom are Black. Critics argued the ruling perpetuated systemic racism by upholding convictions obtained through a procedure with acknowledged racist origins. The decision also significantly curtailed federal habeas review by foreclosing the watershed exception, limiting the ability of federal courts to remedy constitutional violations in final state convictions. Some states, including Louisiana, subsequently considered legislative remedies for affected prisoners.