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Law School Case Brief

Apodaca v. Oregon - 406 U.S. 404, 92 S. Ct. 1628 (1972)

Rule:

The Supreme Court's inquiry in determining whether U.S. Const. amend. VI requires a unanimous verdict in a criminal case must focus upon the function served by the jury in contemporary society. The purpose of trial by jury is to prevent oppression by the government by providing a safeguard against the corrupt or overzealous prosecutor and against the compliant, biased, or eccentric judge. Given this purpose, the essential feature of a jury obviously lies in the interposition between the accused and his accuser of the commonsense judgment of a group of laymen . A requirement of unanimity, however, does not materially contribute to the exercise of this commonsense judgment.

Facts:

Defendants Robert Apodaca, Henry Morgan Cooper, Jr., and James Arnold Madden were convicted respectively of assault with a deadly weapon, burglary in a dwelling, and grand larceny before separate Oregon juries, all of which returned less-than-unanimous verdicts. were convicted in a state court of assault with a deadly weapon, burglary in a dwelling, and grand larceny upon less than unanimous jury verdicts. Apodaca and Madden were convicted by jury votes of 11 to 1, while while the vote in the case of Cooper was 10-2, the minimum requisite vote under Oregon law for sustaining a conviction. The convictions were affirmed by the Oregon Court of Appeals of Oregon and review was denied by the Supreme Court of Oregon. Defendants filed a petition for a writ of certiorari with the United States Supreme Court in which they sought review of their convictions on the grounds that conviction of crime by a less-than-unanimous jury violates the right to trial by jury in criminal cases specified by the Sixth Amendment and made applicable to the States by the Fourteenth Amendment. 

Issue:

Did U.S. Const. amend VI require a conviction by a unanimous verdict?

Answer:

No

Conclusion:

The  United States Supreme Court affirmed petitioners' convictions and held that U.S. Const. amend VI did not require a conviction by a unanimous verdict. The Supreme Court's inquiry in determining whether U.S. Const. amend. VI requires a unanimous verdict in a criminal case must focus upon the function served by the jury in contemporary society. The purpose of trial by jury is to prevent oppression by the government by providing a safeguard against the corrupt or overzealous prosecutor and against the compliant, biased, or eccentric judge. Given this purpose, the essential feature of a jury obviously lies in the interposition between the accused and his accuser of the commonsense judgment of a group of laymen . A requirement of unanimity, however, does not materially contribute to the exercise of this commonsense judgment.

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