Watkins v. Ackley

Summary

The court held that Oregon’s post-conviction statute requires relief for a constitutional violation that is consequential and fundamentally unfair, even when the constitutional rule was announced after the conviction became final. A conviction based on a nonunanimous felony-jury verdict meets that standard because unanimity is essential to a fair and reliable jury trial. The case was returned for further proceedings because the lower court denied relief solely on the ground that the rule did not apply to final convictions.