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Thomas R. Newman and Steven J. Ahmuty Jr. Thomas R. Newman and Steven J. Ahmuty Jr.

In 48 states and federal court, a unanimous jury verdict is required for a criminal conviction for a serious offense. Louisiana (until recently) and Oregon permitted a conviction on a 10-2 verdict. In Apodaca v. Oregon, 406 U.S. 404 (1972), and its companion case, Johnson v. Louisiana, 406 U.S. 356 (1972) (collectively Apodaca), a plurality of the U.S. Supreme Court held that although the Sixth Amendment right to trial by jury requires a unanimous jury verdict in federal criminal trials, it does not require a unanimous verdict in state criminal trials.

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