Ramos v. Louisiana (2019)

Docket: 18-5924
Decided: 2019-01-01
Public Good score: 92 / 100
Framers' Intent score: 82 / 100

Summary

Question: Does the Fourteenth Amendment fully incorporate the Sixth Amendment guarantee of a unanimous verdict against the states? Conclusion: The Sixth Amendment, as incorporated against the states, requires that a jury find a criminal defendant guilty by a unanimous verdict. Justice Neil Gorsuch authored the primary opinion. In Part I, Justice Neil Gorsuch (writing for a majority: himself and Justices Ruth Bader Ginsburg, Stephen Breyer, Sonia Sotomayor, and Brett Kavanaugh) noted that the original public meaning of the Sixth Amendment's right to trial by jury, as well as its history, support an interpretation that it requires guilt be determined by a unanimous jury. Because this right is “fundamental to the American scheme of justice,” it is incorporated against the states (that is, it applies to state governments as well) by the Due Process Clause of the Fourteenth Amendment. Thus, the Sixth Amendment requires a unanimous verdict to support a conviction in state court. In Part II-A, Justice Gorsuch, writing for the same majority, explained how the Court’s jurisprudence came to allow Oregon and Louisiana to permit non-unanimous jury verdicts, describing the fractured plurality opinions in those cases (Apodaca v. Oregon and Johnson v. Louisiana) with a fifth vote from Justice Lewis Powell that was “neither here nor there” but effectively permitted those states to proceed with non-unanimous jury verdicts. In Part II-B, Justice Gorsuch wrote for a plurality of the Court (himself, and Justices Ginsburg, Breyer, Sotomayor), describing the confusion surrounding the Apodaca decision and the apparent conflict in the Court’s precedent as to whether the Sixth Amendment requires unanimous jury verdicts. In Part III, Justice Gorsuch, again writing for the majority, rejected Louisana’s arguments for non-unanimous jury verdicts, finding that the drafting history of the Sixth Amendment is ambiguous at best, the Apodaca plurality’s reasoning was “skimpy,” and most importantly, that the Apodaca plurality “subjected the ancient guarantee of a unanimous jury verdict to its own functionalist assessment.” In Part IV-A, Justice Gorsuch, writing for a plurality (himself and Justices Ginsburg and Breyer), addressed the dissent’s argument that the principle of stare decisis required the Court to stand by its decision in Apodaca and uphold Louisiana’s non-unanimous jury law. Justice Gorsuch argued that under no view can the plurality opinion in Apodaca be controlling on today’s Court. Writing again for a majority in Part IV-B-1, Justice Gorsuch noted that even if the Court accepted the premise that Apodaca established a precedent, no one on the Court today would say it was rightly decided, and “stare decisis isn’t supposed to be the art of methodically ignoring what everyone knows to be true.” For the four-justice plurality (Justice Kavanaugh did not join this part), Justice Gorsuch in Part IV-B-2 addressed the reliance interest Louisiana and Oregon have in the security of their final criminal judgments. Justice Gorsuch minimized the significance of the state’s reliance interests and pointed instead to the reliance interests of the American people in having a just criminal jury that uniformly requires a unanimous verdict for a finding of guilt. Justice Sotomayor filed an opinion concurring as to all but Part IV-A, writing separately to raise three points: “First, overruling precedent here is not only warranted, but compelled. Second, the interests at stake point far more clearly to that outcome than those in other recent cases. And finally, the racially biased origins of the Louisiana and Oregon laws uniquely matter here.” Justice Brett Kavanaugh wrote an opinion concurring in part to explain his view of how stare decisis applies in this case, laying out seven factors, which he argued, support overruling Apodaca in this case. Justice Clarence Thomas filed an opinion concurring in the judgment. Justice Thomas noted from the outset that the Sixth Amendment right to trial by jury includes protection against non-unanimous jury verdicts and would thus resolve the question there. He would further find that the Sixth Amendment's right to a jury trial requires a unanimous verdict to support a conviction in federal court, but would find that the Privileges or Immunities Clause incorporates it against the states. Justice Samuel Alito filed a dissenting opinion, in which Chief Justice John Roberts joined, and which Justice Elena Kagan joined as to all but Part III-D. Justice Alito argued that stare decisis requires following Apodaca and that in overruling that case, the majority “cast[] aside an important and long-established decision with little regard for the enormous reliance the decision has engendered.” In the part of the dissent that Justice Kagan did not join

Case Brief

Facts

Defendant Ramos was convicted of second-degree murder in Louisiana by a non-unanimous 10-2 jury. Louisiana, along with Oregon, permitted non-unanimous jury verdicts for felony convictions under state law. Ramos challenged his conviction, arguing the Sixth Amendment and Fourteenth Amendment require unanimous jury verdicts in state criminal trials.

Procedural History

After Ramos was convicted in a Louisiana state court, the Louisiana Supreme Court affirmed his conviction, relying on precedents from Apodaca v. Oregon and Johnson v. Louisiana. The U.S. Supreme Court granted certiorari to determine whether the Sixth Amendment's jury trial guarantee applies to states through the Fourteenth Amendment.

Issue

Does the Fourteenth Amendment fully incorporate the Sixth Amendment's guarantee of a unanimous jury verdict in criminal trials against state governments?

Holding

Yes. The Sixth Amendment, as incorporated against the states by the Due Process Clause of the Fourteenth Amendment, requires a unanimous jury verdict to support a criminal conviction in state courts.

Rule

The right to a unanimous jury verdict in criminal trials is fundamental to the American scheme of justice and thus incorporated against the states via the Fourteenth Amendment's Due Process Clause. Overruling Apodaca v. Oregon and Johnson v. Louisiana, the Court held that non-unanimous verdicts violate the constitutional guarantee.

Reasoning

The Court analyzed the original public meaning of the Sixth Amendment and found unanimous juries were historically required. The fractured Apodaca precedent was not controlling as it lacked a majority rationale, and the Court rejected its 'functionalist assessment' of ancient jury tradition. The Court emphasized that stare decisis does not require perpetuating a flawed precedent that undermines a fundamental right.

Significance

The decision overruled 50 years of precedent, requiring all states to adopt unanimous jury verdicts for felony convictions, thereby aligning state practice with the Constitution's original meaning. It reinforced the 'fundamental fairness' standard for incorporation under the Fourteenth Amendment and underscored historical methodology in constitutional jurisprudence.

Public Good Analysis

GPT: This decision prevents wrongful convictions and addresses historical racial bias in non-unanimous jury verdicts, strengthening democratic fairness and protecting vulnerable defendants through fundamental jury trial rights. | Claude: This decision strengthens the fundamental right to a jury trial and ensures greater protection against wrongful convictions. Requiring unanimous verdicts increases reliability and fairness in criminal proceedings, safeguarding liberty for all defendants. The concurring opinions highlighting racial bias in the origins of non-unanimous verdict laws further bolsters the public benefit.

Framers' Intent Analysis

GPT: The ruling aligns with the framers' original understanding of jury unanimity as a core 'fundamental' right, rooted in natural law philosophy (e.g., Locke's influence) and colonial precedent, rejecting the Court's 1972 Apodaca precedent as inconsistent with the Sixth Amendment's text and historical meaning. | Claude: The majority opinion correctly grounds the right to a unanimous jury verdict in the original understanding of the Sixth Amendment and its historical application. While the incorporation method via the Fourteenth Amendment’s Due Process Clause is a later development, the core right itself aligns with principles articulated by framers like James Wilson who emphasized the importance of robust protections for the accused. However, Justice Thomas's concurrence using the Privileges or Immunities clause offers a stronger textual alignment with original intent.

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