The Sixth Amendment guarantees several crucial rights in criminal prosecutions, including the right to a speedy and public trial, an impartial jury, and effective assistance of counsel. Recent cases have further refined these protections.
- Ramos v. Louisiana (2020): This landmark decision overturned precedent by ruling that the Sixth Amendment right to a jury trial, as incorporated against the states through the Fourteenth Amendment, requires a unanimous verdict to convict a defendant of a serious offense. This decision invalidated laws in Louisiana and Oregon that allowed non-unanimous jury verdicts in criminal cases, emphasizing the importance of jury unanimity in ensuring fair trials[5].
- Edwards v. Vannoy (2021): Following Ramos, the Court addressed whether the rule requiring unanimous jury verdicts should apply retroactively to cases on federal collateral review. In a 6-3 decision, the Court held that the Ramos rule does not apply retroactively, limiting its impact to cases that were still pending on direct review when Ramos was decided[6].
- Garza v. Idaho (2019): Although slightly outside our four-year window, this case’s impact continues to be felt. The Court held that a defendant’s lawyer cannot override their client’s wish to appeal a conviction just because the defendant signed an appeal waiver. This decision reinforced the importance of a defendant’s autonomy in deciding whether to appeal, even in the face of a plea agreement[7].
- United States v. Haymond (2019): Another case with ongoing significance, Haymond addressed the right to a jury trial in the context of supervised release revocation. The Court held that a provision of federal law allowing judges to impose additional prison time based on a preponderance of the evidence standard violated the Fifth and Sixth Amendment rights to due process and a jury trial[8].
- McCoy v. Louisiana (2018): While decided in 2018, this case continues to influence Sixth Amendment jurisprudence. The Court ruled that it is unconstitutional for defense counsel to concede a defendant’s guilt over the defendant’s express objection, even if the lawyer believes this strategy gives the defendant the best chance of avoiding the death penalty. This decision underscored the defendant’s autonomy in deciding the objectives of their defense[9].
These cases collectively reinforce the fundamental nature of Sixth Amendment protections, particularly emphasizing the roles of juries and defendants’ autonomy in criminal proceedings. They demonstrate the Court’s ongoing effort to balance the rights of the accused with the practical realities of the criminal justice system.