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Ramos v. Louisiana

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Supreme Court of the United States
Ramos v. Louisiana
Term: 2019
Important Dates
Argument: October 7, 2019
Decided: April 20, 2020
Outcome
Reversed
Vote
6-3
Majority
Neil Gorsuch • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Sonia Sotomayor • Brett Kavanaugh
Concurring
Sonia Sotomayor (in part) • Brett Kavanaugh (in part) • Clarence Thomas (in the judgment)
Dissenting
Samuel Alito • Chief Justice John G. Roberts • Elena Kagan


Ramos v. Louisiana is a case argued before the Supreme Court of the United States on October 7, 2019, during the court's October 2019-2020 term. The case came on a writ of certiorari to the Louisiana 4th Circuit Court of Appeal.

The court reversed the Louisiana 4th Circuit Court of Appeal's decision in a 6-3 ruling, holding "if the Sixth Amendment’s right to a jury trial requires a unanimous verdict to support a conviction in federal court, it requires no less in state court." In its ruling, the U.S. Supreme Court overruled a 1972 SCOTUS case, Apodaca v. Oregon.[1] Click here for more information.

HIGHLIGHTS
  • The case: In 2016, Evangelisto Ramos was convicted of murder and sentenced to life imprisonment on a 10 to 12 jury verdict. He appealed his conviction to the Louisiana Fourth Circuit Court of Appeal, arguing his conviction by a non-unanimous jury violated his federal constitutional rights. The court of appeal affirmed Ramos' conviction and sentence. The Louisiana Supreme Court denied review.
  • The issue: Whether the Fourteenth Amendment fully incorporates the Sixth Amendment guarantee of a unanimous verdict?
  • The outcome: The court reversed the Louisiana 4th Circuit Court of Appeal's decision in a 6-3 ruling, holding "if the Sixth Amendment’s right to a jury trial requires a unanimous verdict to support a conviction in federal court, it requires no less in state court."[1]


    • You can review the lower court's opinion here.

    Timeline

    The following timeline details key events in this case:

    • April 20, 2020: The U.S. Supreme Court reversed the Louisiana 4th Circuit Court of Appeal's decision.
    • October 7, 2019: Oral argument
    • March 18, 2019: The U.S. Supreme Court agreed to hear the case.
    • September 7, 2018: Evangelisto Ramos, the petitioner, filed a petition with the U.S. Supreme Court.
    • November 2, 2017: The Louisiana 4th Circuit Court of Appeal affirmed Ramos' conviction and sentence.

    Background

    On May 21, 2015, Evangelisto Ramos was charged with second-degree murder. He pleaded not guilty. In June 2016, 10 members of the 12-member jury found the government had proven its case against Ramos. The other two members disagreed. The jury found Ramos guilty of second-degree murder. He was sentenced to life imprisonment without the possibility of parole.[2][3]

    Ramos appealed his case, arguing there was insufficient evidence to support his conviction. He also argued his conviction by a non-unanimous jury violated his federal constitutional rights. The Louisiana 4th Circuit Court of Appeal rejected Ramos' argument, affirming his conviction and sentence. Ramos sought review from the Louisiana Supreme Court. He was denied.[3]

    In the petition for a writ of certiorari, Ramos argued, "The law is clear: under the Sixth Amendment, a unanimous jury is required. ... The Fourteenth Amendment should incorporate the Sixth Amendment’s guarantee of a unanimous jury."[3]

    The Sixth Amendment

    See also: Bill of Rights, United States Constitution

    The Sixth Amendment of the United States Constitution reads:

    “ In all criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury of the State and district wherein the crime shall have been committed, which district shall have been previously ascertained by law, and to be informed of the nature and cause of the accusation; to be confronted with the witnesses against him; to have compulsory process for obtaining witnesses in his favor, and to have the Assistance of Counsel for his defence.[4] ”

    Questions presented

    The petitioner presented the following questions to the court:

    Questions presented:
    • Whether the Fourteenth Amendment fully incorporates the Sixth Amendment guarantee of a unanimous verdict?[5]

    Outcome

    In a 6-3 opinion, the court reversed the judgment of the Louisiana 4th Circuit Court of Appeal, holding "if the Sixth Amendment’s right to a jury trial requires a unanimous verdict to support a conviction in federal court, it requires no less in state court."[1]

    Justice Neil Gorsuch delivered the opinion of the court with respect to Parts I, II–A, III, and IV–B–1, in which Justices Ruth Bader Ginsburg, Stephen Breyer, Sonia Sotomayor, and Brett Kavanaugh joined; an opinion with respect to Parts II–B, IV–B–2, and V, in which Justices Ginsburg, Breyer, and Sotomayor joined; and an opinion with respect to Part IV–A, in which Justices Ginsburg and Breyer joined.

    Justice Sotomayor filed an opinion concurring as to all but Part IV–A. Justice Kavanaugh filed an opinion concurring in part. Justice Thomas filed an opinion concurring in the judgment.

    Justice Samuel Alito filed a dissenting opinion, in which Chief Justice John Roberts joined, and in which Justice Elena Kagan joined as to all but Part III–D.

    Opinion

    Justice Neil Gorsuch delivered the opinion of the court.

    Parts I, II–A, III, and IV–B–1

    Justices Ruth Bader Ginsburg, Stephen Breyer, Sonia Sotomayor, and Brett Kavanaugh joined with respect to Parts I, II–A, III, and IV–B–1.

    In his opinion, Justice Gorsuch concluded that the 6th Amendment's right to a jury trial—as incorporated by way of the 14th Amendment—requires a unanimous verdict to convict a defendant.

    In his opinion, Justice Gorsuch wrote:

    “ The text and structure of the Constitution clearly suggest that the term 'trial by an impartial jury' carried with it some meaning about the content and requirements of a jury trial. One of these requirements was unanimity.[4] ”
    —Neil Gorsuch[1]

    Gorsuch also concluded that the U.S. Supreme Court had repeatedly recognized this requirement and that the 6th Amendment right was incorporated into the states via the 14th Amendment.

    “ In all, this Court has commented on the Sixth Amendment’s unanimity requirement no fewer than 13 times over more than 120 years. ... This Court has long explained that the Sixth Amendment right to a jury trial is 'fundamental to the American scheme of justice' and incorporated against the States under the Fourteenth Amendment.[4] ”
    —Neil Gorsuch[1]

    Parts II–B, IV–B–2, and V

    Justices Ginsburg, Breyer, and Sotomayor joined with respect to Parts II–B, IV–B–2, and V.

    The court concluded that a "ruling for Louisiana would invite other States to relax their own unanimity requirements."[1]

    In his opinion, Justice Gorsuch wrote of the dissent:

    “ Taken at its word, the dissent would have us discard a Sixth Amendment right in perpetuity rather than ask two States to retry a slice of their prior criminal cases. Whether that slice turns out to be large or small, it cannot outweigh the interest we all share in the preservation of our constitutionally promised liberties.[4] ”
    —Neil Gorsuch[1]

    Part IV–A

    Justices Ginsburg and Breyer joined with respect to Part IV–A.

    The court concluded that Apodaca v. Oregon, a case the U.S. Supreme Court decided in 1972, did not have precedential force. The U.S. Supreme Court ruled in a four-justice plurality in Apodaca that the costs of requiring a unanimous verdict outweighed the benefits. The fifth justice, Lewis Powell, held the 6th Amendment protected the right to a unanimous jury, but that this right was not extended to or required by the states under the 14th Amendment.[1]

    Justice Gorsuch wrote that to accept Apodaca as precedential would mean "we would have to embrace a new and dubious proposition: that a single Justice writing only for himself has the authority to bind this Court to propositions it has already rejected." If that were the case, "every occasion on which the Court is evenly split would present an opportunity for single Justices to overturn precedent to bind future majorities."[1]

    Concurring opinion

    Justice Sotomayor

    Justice Sotomayor filed an opinion concurring as to all but Part IV–A. In her concurring opinion, Justice Sotomayor wrote:

    “ Where the State’s power to imprison those like Ramos rests on an erroneous interpretation of the jury-trial right, the Court should not hesitate to reconsider its precedents.[4] ”
    —Justice Sotomayor[1]

    Justice Kavanaugh

    Justice Kavanaugh filed an opinion concurring in part. In his concurring opinion, Justice Kavanaugh agreed with the decision to overrule Apodaca. He also wrote that the origins of Louisiana's non-unanimous jury law should matter: {{But the question at this point is not whether the Constitution prohibits non-unanimous juries. It does. Rather, the disputed question here is whether to overrule an erroneous constitutional precedent that allowed non-unanimous juries. And on that question—the question whether to overrule—the Jim Crow origins and racially discriminatory effects (and the perception thereof ) of non-unanimous juries in Louisiana and Oregon should matter and should count heavily in favor of overruling, in my respectful view. After all, the non-unanimous jury 'is today the last of Louisiana’s Jim Crow laws.'|author=Justice Kavanaugh[1]}}

    Justice Thomas

    Justice Thomas filed an opinion concurring in the judgment. In his concurring opinion, Justice Thomas wrote:

    “ I would resolve this case based on the Court’s longstanding view that the Sixth Amendment includes a protection against nonunanimous felony guilty verdicts, without undertaking a fresh analysis of the meaning of 'trial . . . by an impartial jury.' I also would make clear that this right applies against the States through the Privileges or Immunities Clause of the Fourteenth Amendment, not the Due Process Clause.[4] ”
    —Justice Thomas[1]

    Dissenting opinion

    Justice Samuel Alito filed a dissenting opinion, in which Chief Justice John Roberts joined, and in which Justice Elena Kagan joined as to all but Part III–D.

    In his dissent, Justice Alito argued that the decision in Apodaca had "elicited enormous and entirely reasonable reliance" and should not be overruled. Alito disagreed with the majority's opinion that Apodaca was not a precedent. He also said the court "tar[red] Louisiana and Oregon with the charge of racism for permitting nonunanimous verdicts."[1]

    Text of the opinion

    Read the full opinion here.

    Oral argument

    Audio

    Audio of oral argument:[6]



    Transcript

    See also

    External links

    Footnotes

    1. ↑ 1.00 1.01 1.02 1.03 1.04 1.05 1.06 1.07 1.08 1.09 1.10 1.11 1.12 Supreme Court of the United States, Ramos v. Louisiana, decided April 20, 2020
    2. ↑ Louisiana Fourth Circuit Court of Appeal, State of Louisiana v. Evangelisto Ramos, decided November 2, 2017
    3. ↑ 3.0 3.1 3.2 Supreme Court of the United States, "Petition for a writ of certiorari," September 7, 2018
    4. ↑ 4.0 4.1 4.2 4.3 4.4 4.5 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    5. ↑ Supreme Court of the United States, "Questions presented: 18-5924 Ramos v. Louisiana," accessed June 7, 2019
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio, Ramos v. Louisiana," accessed October 22, 2019
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