Edwards v. Vannoy

141 S. Ct. 1547 (2021)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

Edwards (P) and an accomplice kidnapped Eaton, a student at LSU. They drove with Eaton to an ATM where they hoped to withdraw money using Eaton’s card. When they discovered that Eaton did not have any money in his account, they drove to Eaton’s apartment. Once there, they bound and blindfolded Eaton, rummaged through his apartment, and took some of his belongings to Eaton’s car. P and his accomplice coerced Eaton into arranging a meeting with Eaton’s girlfriend. At gunpoint, forced Eaton to knock on her door. When Eaton’s girlfriend opened the door, P and his accomplice rushed inside. Both were armed, and P’s accomplice had his gun drawn. P and his accomplice instructed Eaton, Eaton’s girlfriend, and two other women in the apartment to lie on the floor. P then raped one of the women. His accomplice raped another woman. As they left, they grabbed some personal property from the apartment. Pand his accomplice hurried back into Eaton’s car and drove around the corner. They then abandoned the car and fled. Two days later, Pand his accomplice confronted another man at gunpoint and forced him to withdraw money from an ATM. Before the police could arrest P, P turned himself in to the police and confessed to his crimes. P was indicted in Louisiana state court for armed robbery, kidnapping, and rape. P pled not guilty. The jury convicted P of five counts of armed robbery, two counts of kidnapping, and one count of rape. The jury convicted by an 11-to-1 vote on one of the armed robbery counts, the two kidnapping counts, and the rape count. The jury convicted by a 10-to-2 vote on the four remaining armed robbery counts. The judge sentenced P to life imprisonment without parole. The Louisiana First Circuit Court of Appeal affirmed the conviction and sentence. In March 2011, P’s conviction became final on direct review. P applied for state post-conviction relief in the Louisiana courts. Relief was denied. The U. S. Court of Appeals for the Fifth Circuit denied a certificate of appealability. D then petitioned for a writ of certiorari in this Court, arguing that the Constitution requires a unanimous jury in state criminal trials. The Court decided Ramos. The Court held that the Fourteenth Amendment incorporates the Sixth Amendment right to a unanimous jury against the States. For Louisiana and Oregon, the issue became does Ramos apply retroactively to overturn final convictions on federal collateral review? The granted certiorari in P’s case to decide that question.