Stephen Miller and Leigh Ann Benson contributed an article to The Legal Intelligencer discussing how earlier this year, only two states still permitted nonunanimous jury convictions—Louisiana and Oregon. The U.S. Supreme Court’s Ramos v. Louisiana decision in April 2020 held that unanimity is required under the Sixth Amendment. They explain how that decision applied only to cases on direct appeal; it did not apply to cases under collateral review (i.e., habeas corpus petitions filed after direct appeals were exhausted).
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