Just like most of the famous movie scenes, there is a lot of drama surrounding the jury's deliberation. There are many factors at play including but not limited to: the jurors and their backgrounds, the evidence presented at trial, the popularity of the case, and the subject matter may be too gruesome for some. Nevertheless, the unanimous jury verdict has been a strict requirement for federal criminal proceedings.
The Sixth Amendment guarantees a criminal defendant the right to an "impartial" jury. The Constitution does not clearly use the word "unanimous." However, the majority of state courts have held that impartial means a unanimous jury verdict.
But history shows that individual states have convicted defendants with non-unanimous jury verdicts. These decisions seem to trend 10-2 in favor of conviction. Some of these criminal defendants were sentenced to life without parole on a nonunanimous jury decision. Specifically, Louisiana and Oregon are the only states that were still allowing these decisions. At the state court level, Mr. Ramos committed a serious crime and was convicted to life without parole by a 10-2 jury decision. He appealed the lower courts' rulings all the way up to the Supreme Court. Mr. Ramos argued that "his conviction by a nonunanimous jury as an unconstitutional denial of the Sixth Amendment right to a jury trial."
Recently, in 2020, the Supreme Court, in Ramos v. Louisiana, finally ruled that states must obtain unanimous jury verdicts to convict state criminal defendants. While this is a giant step forward, there is another case pending before the Supreme Court that asks them to decide whether their Ramos decision applies retroactively. "That's why more than 1,500 people in Louisiana are still imprisoned on non-unanimous verdicts-- a law that originated in the Jim Crow era to reestablish the supremacy of the white race." In the Ramos opinion, the Court contemplated the pros and cons of this decision that overruled prior precedent, Apodaca v. Oregon, and concluded that the pros outweigh the cons here. Following that line of reasoning, it seems like the Court is attempting to make up for its prior mistakes, which means this ruling should apply retroactively.
Concurring in the Ramos decision, Justice Kavanaugh articulated his own test for determining when it is appropriate to overturn a previous constitutional decision. He drew a distinction between statutory and constitutional cases. He said that the legislature can amend statutes, but it is up to the Supreme Court to apply the doctrine of stare decisis broadly. The only other way a constitutional interpretation could be amended or corrected would be through a formal constitutional amendment which is extremely unlikely.
The main takeaway from Ramos is that ALL states must tell juries their decisions need to be unanimous to convict a criminal defendant in order to protect their Sixth Amendment right. Since the majority of states already followed this rule, it is not much of a change. But for Louisiana and Oregon, they have to amend their criminal procedure. Additionally, the Supreme Court relied on the incorporation doctrine to ensure federal rights apply across all states.
Now all criminal defendants can know for sure that the jury on their case would fairly and equitably make their decision based on all facts presented during trial. This is a huge step in the right direction!
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