Court: U.S. Supreme Court
Judgment Date: 20 April 2020
Where Reported: 140 S. Ct. 1390, 206 L.Ed.2d 583
Legal Issue in Ramos v Louisiana
The central legal issue in Ramos v Louisiana was whether the Sixth Amendment’s requirement for unanimous jury verdicts in federal criminal trials also applied to state criminal trials.
This issue arose because Louisiana and Oregon allowed non-unanimous verdicts in certain cases, which challenged the traditional understanding of the Sixth Amendment.
Ramos v Louisiana specifically questioned whether non-unanimous jury verdicts in state criminal trials violated the constitutional rights of the defendant under the Sixth Amendment as incorporated by the Fourteenth Amendment.
Material Facts in Ramos v Louisiana
Evangelisto Ramos was convicted of murder in Louisiana in 2016 by a 10-2 jury vote, prior to the state’s constitutional amendment requiring unanimous jury verdicts for crimes committed after January 1, 2019.
Louisiana, along with Oregon, permitted non-unanimous jury verdicts for serious crimes, a practice rooted in their historical racial discrimination policies.
Ramos appealed his conviction, challenging the constitutionality of non-unanimous jury verdicts. He argued that the law, established in 1898, was a Jim Crow law that allowed racial discrimination within juries.
The Louisiana Court of Appeal upheld his sentence in November 2017. Ramos then petitioned to the U.S. Supreme Court, questioning whether the Fourteenth Amendment fully incorporates the Sixth Amendment guarantee of a unanimous verdict.
Judgment in Ramos v Louisiana
In a 6-3 decision, the Supreme Court ruled in favour of Ramos, overturning his conviction.
The Court held that the Sixth Amendment’s requirement of a unanimous jury vote for conviction in serious crimes must also be applied against the states, thereby overturning the earlier ruling in Apodaca v Oregon.
Justice Gorsuch wrote the majority opinion, asserting that the guarantee of a unanimous jury verdict is incorporated by the Due Process Clause of the Fourteenth Amendment.
Justice Clarence Thomas concurred with the judgment but argued for incorporation by the Privileges or Immunities Clause of the Fourteenth Amendment.
The decision affected only Louisiana and Oregon, as all other states already required unanimous verdicts.
The Reason for Decision in Ramos v Louisiana
The Supreme Court’s decision was based on an interpretation of the Sixth Amendment’s historical context and its application through the Fourteenth Amendment.
The majority opinion, written by Justice Gorsuch, emphasised that the text and structure of the Constitution implied that the term “trial by an impartial jury” included the requirement of a unanimous verdict, a principle deeply rooted in common law and early American state practices.
This understanding was reinforced by historical treatises and the Court’s own precedent, which had consistently commented on the Sixth Amendment’s unanimity requirement.
The Court also critically examined the precedents set by Apodaca v Oregon and Johnson v Louisiana.
In Apodaca, a plurality of the Court had concluded that unanimity was not essential in state trials, but this reasoning was based on a dual-track incorporation theory, which the Court had largely rejected.
Justice Gorsuch pointed out that this earlier decision did not provide a compelling reason to depart from the historical understanding of the Sixth Amendment.
Moreover, the ruling in the Apodaca case was considered poorly reasoned and inconsistent with the Court’s established interpretation of the Sixth Amendment and the incorporation doctrine.
The majority opinion in Ramos v Louisiana also acknowledged the discriminatory origins of non-unanimous jury verdicts in Louisiana and Oregon, noting that these practices were part of broader Jim Crow laws designed to undermine African-American participation in the judicial process.
The Court rejected the notion of conducting a cost-benefit analysis on the historic features of common law jury trials, as it would undermine the fundamental rights enshrined in the Constitution.
The Court determined that the Sixth Amendment’s requirement for a unanimous jury verdict was fundamental to the American scheme of justice and must be applied to state trials through the Fourteenth Amendment’s Due Process Clause.
Conclusion
The Ramos v Louisiana decision marked a significant shift in the interpretation of the Sixth Amendment’s application to state criminal trials.
The Supreme Court affirmed the fundamental nature of a unanimous jury verdict in serious criminal cases, reinforcing the principle of equal protection under the law.
By overturning Apodaca v Oregon, the Court rectified a longstanding inconsistency in the application of the Sixth Amendment and addressed a discriminatory practice rooted in a historical context of racial injustice.
This decision in Ramos v Louisiana not only impacted the specific cases in Louisiana and Oregon but also emphasised the importance of adhering to the historical and constitutional context in interpreting the Bill of Rights.
The ruling highlights the Court’s role in ensuring that constitutional protections are uniformly applied across all states, thereby upholding the principles of justice and equality under the law.
