State v. Doyle

In Ramos, the United States Supreme Court held that the Sixth Amendment requires a unanimous jury verdict to convict.

Defendant appealed, on remand from the Oregon Supreme Court, a conviction of Sexual Abuse in the First-Degree. Defendant assigned error to the trial court’s denial of a request for a unanimous jury instruction. In Doyle I, the court dismissed the jury instruction error, but because of Ramos v. Louisiana, the court reheard the appeal and applied the rationale from Ramos. On remand, Defendant renewed his argument that the United States Constitution demands a unanimous jury verdict and failure to instruct the jury to that end was an error and a violation of the Sixth and Fourteenth Amendments. In response, the State argued that because the jury was not polled, the error was harmless. In Ramos, the United States Supreme Court held that the Sixth Amendment requires a unanimous jury verdict to convict. The Court, therefore, held that the trial court erred when it instructed the jury that a nonunanimous verdict was permitted. The Court rejected the harmlessness argument because the State did not meet its burden of proof beyond a reasonable doubt. Reversed and remanded.