Last term, in Ramos v. Louisiana, 590 U.S. ___, 140 S. Ct. 1390 (2020), the U.S. Supreme Court held by a 6-3 vote that the Sixth Amendment right to trial by jury, as incorporated against the states by way of the 14th Amendment, requires a unanimous verdict to convict a defendant of a serious offense in a state criminal trial. Ramos overruled Apodaca v. Oregon, 406 U.S. 404 (1972), in which a plurality of the court held that the Sixth Amendment required unanimous jury verdicts in federal trials but not state trials.