## Facts

- Evangelisto Ramos was tried in Louisiana state court for second-degree murder and elected a jury trial.
- The jury returned a 10–2 verdict finding Ramos guilty.
- Louisiana law at the time permitted conviction for serious offenses by a non-unanimous jury vote.
- Ramos was sentenced to life imprisonment without the possibility of parole.
- Louisiana appellate courts affirmed the conviction, and the state supreme court denied review.
- Ramos sought U.S. Supreme Court review, arguing that the Sixth Amendment requires a unanimous jury verdict and that this requirement applies to the states through the Fourteenth Amendment.
- At the time of Ramos’s case, nearly all jurisdictions required unanimity; Louisiana and Oregon were exceptions allowing non-unanimous felony convictions.

## Issues

1. Whether the Sixth Amendment’s jury-trial guarantee, as applied to the states through the Fourteenth Amendment, requires jury unanimity to convict a defendant of a serious offense.
2. Whether prior precedent permitting non-unanimous state jury convictions should be overruled.

## Decision

- The Supreme Court reversed the state appellate judgment in a 6–3 decision.
- The Court held that the Sixth Amendment requires a unanimous verdict to convict a defendant of a serious offense, and that this rule applies in both federal and state courts.
- The Court overruled prior decisions to the extent they allowed non-unanimous convictions in state criminal trials.
- Justice Gorsuch announced the Court’s judgment; separate concurrences addressed incorporation doctrine and stare decisis, and a dissent argued the precedent should be retained.

## Legal Principles

- The Sixth Amendment right to trial by jury includes a requirement of unanimity for convictions of serious offenses.
- Once incorporated against the states, a constitutional right applies with the same substantive content in state and federal proceedings; states may not apply a narrower version of the right.
- Stare decisis does not require retaining a fractured, poorly reasoned constitutional precedent that conflicts with the Sixth Amendment’s historical meaning and modern incorporation doctrine.

## Conclusion

The Court held that a state may not convict a defendant of a serious crime on a non-unanimous jury verdict, requiring Louisiana and Oregon to conform their jury-conviction rules to the Sixth Amendment unanimity requirement as incorporated by the Fourteenth Amendment.


Ramos v. Louisiana, 590 U.S. 83 (2020)