Edwards v. Vannoy
Can criminal cases be tried again if the criminal justice rules change?
BACKGROUND:
Docket No. 19-5807
Date Argued: Dec 2, 2020
Date Decided: May 17, 2020
In 2009, Thedrick Edwards was charged with five counts of armed robbery, one count of aggravated rape, and two counts of aggravated kidnapping. However, the jury did not unanimously find him guilty, having 10-2 and 11-1 majorities on the charges instead. At this time in Louisiana, a unanimous jury was not required for conviction as long as there was at least a 10-2 majority. So, Thedrick Edwards was found guilty and was sentenced to life imprisonment. The reason this rule was made was because of the Supreme Court Case Apodaca v. Oregon, which stated that state juries can convict without a unanimous verdict in felony criminal cases.
Later when this rule was changed and a unanimous jury was required for a conviction, Edwards filed a petition for a writ of certiorari (asking for his case to be reviewed) to the Supreme Court in 2019. His request was then granted in 2020. As a defense, Edwards had the Supreme Court ruling on the case of Ramos v. Louisiana (2020), where the Supreme Court overruled Apodaca v. Oregon, finding that the Sixth Amendment establishes the right to a unanimous jury in both state and federal courts.
PRESIDING QUESTIONS: In Ramos v. Louisiana, the Supreme Court found that the Sixth Amendment established the right to a unanimous jury in both state and federal courts. Can this ruling apply retroactively to cases on federal collateral review? In other words, can previous trials that did not have a unanimous jury be tried again?
OUTCOME - 6-3 in favor of Vannoy
The main judicial reasoning for this case came from Teague v. Lane (1989). In this case, the court ruled that new rules could not ordinarily apply to previous cases, since this would lead most cases to be reviewed after each and every new rule by the court. However, Teague v. Lane gave one exception to this rule, known as the “watershed” exception. For this exception, new rules can apply to old cases if they make criminal verdicts more accurate and if they improve the fairness of criminal trials. The court found that the rule from Ramos v. Louisiana was both a new rule and a rule that wasn’t “watershed,” so it cannot apply to previous cases.
PARTIES AND OPINIONS
Side 1- Edwards (Petitioner)
Edwards filed a petition for his conviction in 2009 to be reviewed by the Supreme Court.
The central argument was that the ruling in Ramos v. Louisiana fit the description of “watershed,” and thus should apply retroactively to his case.
Side 2- Vannoy (Respondent)
Vannoy was the Warden during Edwards’ arrest.
The main argument is that the “watershed” exception has rarely been used over its three decades of existence. As a result, it doesn’t make sense that any new rulings fall under this category, including the Ramos v. Louisiana ruling that requires a unanimous jury.
Concurring Opinion
The first concurring opinion was from Justice Clarence Thomas. He agreed with the majority opinion, but also stated that the case could have been resolved by using the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). More specifically, federal courts should not intervene unless the state court decision “was contrary to, or involved an unreasonable application of” federal law. Simply put, because the state court’s decision followed federal law from Apodaca v. Oregon, the Supreme Court cannot help Edwards.
The second concurring opinion was from Justice Neil Gorsuch. He agreed with the majority opinion and their criticism of the “watershed” rule. Specifically, he stated that the watershed rule had not been applicable for over three decades and that it gives a “false hope” that new rules can ever be applied to previous cases.
SIGNIFICANCE
While previous cases regarding new criminal justice rules have simply denied “watershed” status to these rules, this case went further. The court ended the “watershed” exception, saying that “no new rules of criminal procedure can satisfy the watershed exception,” and that continuing it would “offer false hope to defendants.”
In the past, even though the chance was slim, defendants had a possibility of creating a new rule through the Supreme Court and righting a potential wrong in their conviction. Now, defendants that have their rights violated cannot benefit when the violation is fixed, leaving them defenseless against Constitutional violations.
Sources
https://ballotpedia.org/Edwards_v._Vannoy#cite_note-petition-3
https://www.scotusblog.com/case-files/cases/edwards-v-vannoy/?wpmp_switcher=desktop
https://www.oyez.org/cases/2020/19-5807
https://interrogatingjustice.org/ending-mass-incarceration/supreme-court-overturns-watershed-exception-to-retroactivity-rule/
https://www.casemine.com/judgement/us/5914b19aadd7b0493475a67a
https://www.oyez.org/cases/1971/69-5046
https://www.law.uw.edu/wlr/print-edition/print-edition/vol-91/2/constitutional-retroactivity-in-criminal-procedure
https://blog.federaldefendersny.org/supreme-court-overrules-the-watershed-rule-of-criminal-procedure-portion-of-teague-v-lane/
(image) https://2255motion.com/teague-v-lane-teague-doctrine/