Ramos v. Louisiana
Facts
Apodaca had permitted States to convict criminal defendants with non-unanimous juries, and Louisiana and Oregon continued using that practice. The opinions state that only those two States employed non-unanimous juries in criminal cases. The challenged practice affected criminal defendants facing imprisonment under state convictions returned without unanimity. The opinions also discuss the historical racist origins of Louisiana's and Oregon's non-unanimous jury laws as an important consideration supporting overruling Apodaca.
Issue
Whether Apodaca v. Oregon should be overruled so that state criminal juries, like federal juries, must return unanimous verdicts to convict a defendant. Also at issue was whether stare decisis justified retaining Apodaca despite its inconsistency with prior Sixth Amendment and incorporation doctrine.
Rule
State criminal juries must be unanimous in order to convict a criminal defendant, and Apodaca v. Oregon should be overruled. In constitutional criminal-procedure cases, stare decisis is weaker where a precedent is egregiously wrong, causes significant negative consequences, and does not generate reliance interests sufficient to justify retaining it.
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