## Facts

- Thedrick Edwards was convicted in Louisiana state court in 2007 of armed robbery, rape, and kidnapping.
- Louisiana law then allowed felony convictions by non-unanimous juries so long as at least 10 of 12 jurors voted to convict.
- Edwards was convicted by split verdicts (11–1 on some counts and 10–2 on others), and his convictions became final on direct review.
- After unsuccessful state postconviction proceedings, Edwards filed a federal habeas petition in 2015, arguing that non-unanimous verdicts violated the Constitution; the claim was rejected under then-controlling precedent permitting non-unanimous state verdicts.
- While Edwards sought Supreme Court review, the Court decided Ramos v. Louisiana (2020), holding that the Sixth Amendment requires unanimous state jury verdicts for serious offenses.
- Edwards then argued that Ramos applied retroactively to his final convictions on federal collateral review.

## Issues

1. Whether the Sixth Amendment jury-unanimity rule announced in Ramos v. Louisiana applies retroactively to cases on federal habeas corpus review.
2. Whether Teague v. Lane’s “watershed” exception for new procedural rules remains available to justify retroactive application on federal collateral review.

## Decision

- The Court held that Ramos announced a new rule of criminal procedure that does not apply retroactively on federal habeas review.
- The Court concluded Ramos was not a substantive rule and therefore could be retroactive only if it qualified as a “watershed” procedural rule under Teague.
- The Court declared the Teague “watershed” exception effectively defunct and stated that, going forward, new rules of criminal procedure will not be applied retroactively on federal collateral review under that exception.
- Applying that framework, the Court denied Edwards federal habeas relief based on his non-unanimous jury convictions.

## Legal Principles

- Under Teague v. Lane, new constitutional rules of criminal procedure generally do not apply retroactively on federal collateral review.
- Teague’s substantive-rule exception applies retroactively when a rule changes the range of conduct or class of persons that the law may punish; procedural rules regulating fact-finding typically do not qualify.
- The Court treated Ramos’s unanimity requirement as procedural, not substantive.
- The Court eliminated Teague’s “watershed” procedural exception as a practical matter, holding that no new procedural rule will qualify for retroactive application on federal habeas under that category.
- Federal habeas retroactivity doctrine prioritizes the finality of state convictions and limits reopening of final judgments based on later procedural decisions.

## Conclusion

The Court held that Ramos’s unanimous-jury requirement is not retroactive on federal habeas review and foreclosed Teague’s “watershed” exception, sharply limiting retroactive relief for new procedural rules in collateral proceedings.


Edwards v. Vannoy, 593 U.S. 255 (2021)