590 U.S. __ (2020).
A 2020 United States Supreme Court opinion in which the Court held that the Sixth Amendment, as applied to the states through the Fourteenth Amendment, requires a unanimous jury verdict for criminal convictions in state court cases. This opinion only impacted state court cases in Oregon as all other states already had unanimity requirement in place at the time of this opinion.
In Edwards v. Vannoy, 141 S.Ct. 1547 (2021), the Supreme Court held that its ruling in Ramos did not apply retroactively to prior final convictions.
People v. Wilson, 56 Cal.App.5th 128 (2020).
In his notice of new authority, Wilson also cites the Supreme Court’s recent decision in Ramos v. Louisiana (2020) ––– U.S. ––––, [140 S.Ct. 1390, 206 L.Ed.2d 583], which held that the Sixth Amendment’s unanimity requirement applies to criminal trials in state courts. Given California’s existing requirement of a unanimous verdict, the Supreme Court’s decision has no direct effect on California and does not change our analysis. Nothing in Ramos suggests that a unanimity instruction was required in this case under the factual circumstances we discuss post.