Edwards v. Vannoy
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Edwards v. Vannoy and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Edwards v. Vannoy.
In Edwards v. Vannoy, the Supreme Court addressed whether the jury-unanimity rule established in Ramos v. Louisiana applies retroactively on federal collateral review. The Court concluded that the Ramos rule does not apply retroactively, as it is not considered a 'watershed' rule of criminal procedure. This decision reaffirms the principle that new procedural rules generally do not apply retroactively on federal collateral review.
Holding
The single most important “bottom line” of what the Court decided in Edwards v. Vannoy.
The Court held that the Ramos jury-unanimity rule does not apply retroactively on federal collateral review.
Constitutional Concepts
These are the Constitution-related themes that appear in Edwards v. Vannoy. Click a concept to see other cases that involve the same idea.
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Why Right to Jury Trial is relevant to Edwards v. Vannoy
The case centers on whether the right to a unanimous jury verdict, as established in Ramos, applies retroactively on federal collateral review.
Syllabus excerpt (verbatim)Edwards fled a federal habeas corpus petition, arguing that the non-unanimous jury verdict violated his constitutional right to a unanimous jury.
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Why Procedural Due Process is relevant to Edwards v. Vannoy
The decision discusses the application of new procedural rules on federal collateral review, which is a due process concern.
Syllabus excerpt (verbatim)A new procedural rule will apply retroactively on federal collateral review only if the new rule constitutes a 'watershed' rule of criminal procedure.
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Why Substantive Due Process is relevant to Edwards v. Vannoy
The discussion of 'watershed' rules of criminal procedure touches on fundamental fairness, a substantive due process issue.
Syllabus excerpt (verbatim)When the Teague Court frst articulated that 'watershed' exception, however, the Court stated that it was 'unlikely' that such watershed 'components of basic due process have yet to emerge.'
Key Quotes
Short excerpts from the syllabus in Edwards v. Vannoy that support the summary and concepts above.
The Ramos jury-unanimity rule does not apply retroactively on federal collateral review.
The Court has stated that new rules of criminal procedure ordinarily do not apply retroactively on federal collateral review.
The watershed exception must 'be regarded as retaining no vitality.'
