Supreme Court of the United States · 2021 · Federal Courts
Reporter Citation Pending
Updated
Federal Courtswatershed rules abolishedretroactivityfederal habeas corpusnew procedural rulesTeaguefederal collateral reviewhabeas
Facts
Edwards was convicted in Louisiana state court of armed robbery, kidnapping, and rape. At the time, Louisiana law allowed conviction by non-unanimous 12-person juries, and Edwards was convicted by votes of 11-1 on some counts and 10-2 on others. His conviction became final in 2011. In federal habeas proceedings, he argued that the Constitution required a unanimous jury, and after Ramos later held that state juries must be unanimous for serious offenses, he argued that Ramos should apply retroactively to his final conviction.
Issue
Does the jury-unanimity rule announced in Ramos v. Louisiana apply retroactively on federal collateral review to convictions that were already final? More broadly, can a new rule of criminal procedure qualify for the Teague watershed exception and apply retroactively in federal habeas?
Rule
A new rule of criminal procedure applies to cases pending in trial courts and on direct review, but it does not apply retroactively on federal collateral review. Ramos announced a new procedural rule, and no new rule of criminal procedure can satisfy the purported Teague watershed exception, which retains no vitality.
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10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
In 2014, a Pennsylvania defendant's conviction for burglary became final after direct review ended. In 2027, the Supreme Court announces a new constitutional rule requiring trial judges to give a specific cautionary instruction before admitting eyewitness-identification testimony. The defendant files a federal habeas petition seeking to vacate his conviction based solely on that new rule.
Should the federal court grant relief?
Explanation. The petition should be denied. The majority held that new procedural rules apply to cases in trial courts and on direct review, but not retroactively on federal collateral review. A new jury-instruction requirement changes the manner of determining culpability, so it is procedural. After this case, a habeas petitioner cannot rely on any watershed exception to obtain retroactive application of a new procedural rule. (Derived from Edwards v. Vannoy (n.d.).)