Edwards v. Vannoy
593 U.S. 255 (2021)
Rule of Law:
New procedural rules of criminal procedure do not apply retroactively on federal collateral review, and the 'watershed' exception to this non-retroactivity principle is explicitly eliminated.
Facts:
- In May 2006, Thedrick Edwards and an accomplice kidnapped a student in Baton Rouge, forcing him to drive to an ATM and then to his apartment.
- Edwards and his accomplice invaded the victim's apartment, where they bound and blindfolded the student, his girlfriend, and two other women.
- During the home invasion, Edwards raped one woman while his accomplice raped another, and they stole personal property before fleeing.
- Two days later, the pair committed another armed robbery involving a different victim at an ATM.
- Edwards surrendered to police and confessed to the crimes on video.
- A Louisiana jury convicted Edwards of armed robbery, rape, and kidnapping.
- Crucially, the jury verdicts were not unanimous; Edwards was convicted by a vote of 11-to-1 on some counts and 10-to-2 on others, which was permitted under Louisiana law at the time.
Procedural Posture:
- Edwards was indicted and tried in Louisiana state trial court.
- The jury convicted Edwards, and the trial court sentenced him to life imprisonment.
- The Louisiana First Circuit Court of Appeal affirmed the conviction.
- The conviction became final on direct review in 2011.
- Edwards filed for state post-conviction relief, which the Louisiana state courts denied.
- Edwards filed a petition for a writ of habeas corpus in the U.S. District Court for the Middle District of Louisiana.
- The District Court denied the petition.
- The U.S. Court of Appeals for the Fifth Circuit denied a certificate of appealability.
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Issue:
Does the constitutional rule requiring unanimous jury verdicts in state criminal trials apply retroactively to overturn final convictions on federal collateral review?
Opinions:
Majority - Justice Kavanaugh
No, the requirement for jury unanimity is a new procedural rule that does not apply retroactively to cases on federal collateral review. The Court applied the framework from Teague v. Lane, which holds that new rules of criminal procedure generally do not apply to convictions that are already final. The Court determined that the rule announced in Ramos v. Louisiana was 'new' because it was not dictated by precedent existing at the time Edwards's conviction became final; in fact, the prior precedent of Apodaca v. Oregon expressly permitted non-unanimous verdicts. While Teague theoretically allowed for an exception for 'watershed' rules of criminal procedure, the Court noted that it has never identified a single rule that satisfies this exception in the 32 years since Teague was decided. Concluding that the exception offers false hope and has no practical application, the Court officially acknowledged that the watershed exception is moribund and must be regarded as retaining no vitality.
Concurring - Justice Thomas
Yes, the denial of relief was correct, but the case should have been resolved solely on the text of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). Under AEDPA, a federal court cannot grant habeas relief unless the state court's adjudication was contrary to clearly established federal law as determined by the Supreme Court at the time. Since Apodaca was the controlling law when the Louisiana court rejected Edwards's claim, the state court's decision was reasonable, and AEDPA bars relief regardless of any retroactivity analysis under Teague.
Concurring - Justice Gorsuch
Yes, the judgment should be affirmed because the writ of habeas corpus traditionally did not function to reopen final judgments of competent courts based on new procedural rules. The concurring opinion argued that Teague's 'watershed' exception was an anomaly that was inconsistent with the historical purpose of habeas corpus. Retiring the watershed exception returns the Court closer to the traditional view that a final judgment of conviction, after the exhaustion of appellate review, should remain final.
Dissenting - Justice Kagan
No, the jury unanimity rule is a textbook example of a watershed rule that should apply retroactively. The dissent argued that the majority's decision to abolish the watershed exception was an unjustified departure from stare decisis. Justice Kagan contended that if any rule ever qualified as 'watershed'—meaning it is essential to the fairness and accuracy of a trial—it is the requirement that a jury be unanimous to convict. By overruling Teague's exception rather than applying it, the Court denies relief to defendants convicted under a system (non-unanimous juries) that the Court itself has deemed fundamentally unfair and racially discriminatory.
Analysis:
This decision effectively closes the door on federal habeas corpus relief based on new rules of criminal procedure. By formally eliminating the 'watershed' exception from Teague v. Lane, the Supreme Court has established a bright-line rule that new procedural rights, no matter how fundamental, will only protect defendants whose cases are still pending on direct review or arise in the future. This prioritizes the finality of convictions and the conservation of judicial resources over the retroactive rectification of procedural constitutional violations, even those deemed essential to a fair trial.
