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Edwards v. Vannoy

141 S. Ct. 1547 (2021)

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Edwards v. Vannoy

United States Supreme Court

141 S. Ct. 1547 (2021)

Facts

Thedrick Edwards (defendant) was tried for robbery, rape, and kidnapping. The jurors returned a nonunanimous guilty verdict with 10 or 11 out of 12 jurors finding Edwards guilty of each crime. After Edwards’s conviction became final, Edwards filed a habeas corpus petition in the federal district court in 2015. Edwards claimed that the nonunanimous jury verdict violated his constitutional right to a unanimous verdict. The district court rejected this claim. Subsequently, the court of appeals denied Edwards a certificate of appealability. Then, Edwards petitioned for a writ of certiorari from the United States Supreme Court. While the petition was pending, the Supreme Court decided Ramos v. Louisiana. In Ramos, the Supreme Court held that the Constitution requires a unanimous jury verdict to convict a criminal defendant in state court. Thus, when the Supreme Court heard the appeal by Edwards, Edwards argued that the new procedural rule requiring unanimous jury verdicts in state court was a watershed rule of criminal procedure, so it ought to be applied retroactively to overturn his conviction. The Supreme Court considered this argument.

Rule of Law

Issue

Holding and Reasoning (Kavanaugh, J.)

Dissent (Kagan, J.)

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