Watkins v. Ackley
Annotate this CaseThe issue this case presented for the Oregon Supreme Court's review centered on the effect of Ramos v. Louisiana, 140 S Ct 1390 (2020) in an appeal of a trial court’s rejection of a post-conviction petitioner’s challenge to convictions that were obtained through nonunanimous verdicts. Petitioner raised the issue as soon as Ramos was decided—but years after the challenged convictions had become final. The issue on appeal thus concerned the “retroactivity” of the constitutional rule announced in Ramos in a post-conviction proceeding under ORS 138.510 to 138.680. The Oregon Court held that when a petitioner seeks post-conviction relief on Sixth Amendment grounds, from a judgment of conviction which was based on a nonunanimous verdict and which became final before the Supreme Court’s Ramos decision issued, the petitioner was entitled to relief— assuming that none of the procedural defenses in the Post-Conviction Hearings Act were raised and sustained. "That is so because convicting a defendant on a nonunanimous jury verdict amounts to a 'substantial denial in the proceedings resulting in petitioner’s conviction *** of petiioner’s rights under the Constitution of the United States *** which denial rendered the conviction void,' for which post-conviction relief 'shall be granted.'”
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