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2. Unanimity

Ramos v. Louisiana, USSC No. 18-5924, 2020 WL 1906545, 4/20/20, reversing State v. Ramos, 231 So. 3d 44 (La. Ct. Apps. 2017); Scotusblog page (including links to briefs and commentary) The holding in this case has no relevance to Wisconsin practitioners, or indeed anyone outside of Louisiana or Oregon–the only two jurisdictions permitting 10-2 guilty… Read more


United States v. Lemurel E. Williams, 7th Circuit Court of Appeals No. 15-1194, 4/26/16 Williams is entitled to a new trial because under the totality of the circumstances, the jury’s continued deliberations after an aborted delivery of the initial verdict were impermissibly coercive. The jury returned a guilty verdict but, during the polling of the jurors, the… Read more


State v. Julian L. Perez, 2013AP750-CR, District 1, 12/10/13; court of appeals decision (not recommended for publication); case activity Where the evidence at trial showed that the defendant possessed a firearm over a short span of time at two locations in the same apartment building, the jury did not need to be unanimous as to… Read more


State v. Carl Mills, 2010AP1746-CR, District 1, 9/7/11 court of appeals decision (not recommended for publication); for Mills: Randall E. Paulson, SPD, Milwaukee Appellate; case activity Trail counsel was not ineffective for failing to object to jury instructions and verdict forms with respect to unanimity on multiple counts of sexual assault of a single victim… Read more