In a significant ruling on June 17, 2026, the Oregon Court of Appeals reversed the conviction of Steven Jay Decker, who had been found guilty of fifteen counts of first-degree sexual abuse. The court determined that the jury's verdicts were nonunanimous, which violated Decker's constitutional rights. This ruling could have far-reaching implications for similar cases involving nonunanimous jury verdicts in Oregon.
The court's decision affects not only Decker but also other individuals who may have been convicted based on nonunanimous jury verdicts. The ruling underscores the importance of unanimous verdicts in the criminal justice system, reinforcing the principle that a defendant's rights must be upheld in accordance with constitutional standards.
Background
Steven Jay Decker was convicted after a jury trial in which he faced fifteen counts of first-degree sexual abuse. Following the trial, the jury returned guilty verdicts on all counts. However, during a poll of the jurors, it was revealed that at least two jurors had voted not guilty. Specifically, Juror #10 stated, "No" when asked if the verdict was their individual verdict, indicating a nonunanimous decision. Additionally, Juror #1 later clarified that she had found Decker guilty on only six counts and not guilty on the remaining nine counts.
After the judgment was finalized, Decker sought post-conviction relief, arguing that the nonunanimous nature of the jury verdicts constituted a denial of his constitutional rights. The case was brought before the Oregon Court of Appeals after the post-conviction court denied his request for relief, leading to Decker's appeal.
The Ruling
The Oregon Court of Appeals, led by Judge Kamins, ruled in favor of Decker, reversing the post-conviction court's decision. The court found that the evidence clearly indicated that at least nine of Decker's guilty verdicts were nonunanimous. The ruling stated, "the record includes a jury poll in which one juror said that a guilty verdict was not his verdict...there is no possible conclusion other than that at least nine of the verdicts in petitioner’s case were nonunanimous." This statement highlights the court's determination that the lack of a unanimous verdict rendered the convictions fundamentally unfair.
The court emphasized that a conviction based on a nonunanimous verdict is a substantial denial of constitutional rights, which warrants post-conviction relief. The opinion stated, "when it is established that a conviction was entered based on a nonunanimous verdict, the proceeding must be recognized as fundamentally unfair, and post-conviction relief must be granted." The judges who joined this opinion included Chief Judge Lagesen and Judges Ortega, Egan, Tookey, Powers, Pagán, Joyce, Hellman, and Jacquot.
Impact
This ruling has significant implications for the legal landscape in Oregon, particularly concerning the validity of nonunanimous jury verdicts. The decision reinforces the constitutional requirement for unanimous verdicts in criminal cases, aligning Oregon's practices with the standards set forth by the U.S. Supreme Court in Ramos v. Louisiana. This case established that the Sixth Amendment requires a unanimous jury verdict to support a conviction.
The ruling may prompt a review of past convictions that were secured through nonunanimous verdicts, potentially leading to new trials or other forms of relief for affected individuals. As a result, this decision could reshape how courts handle similar cases in the future, ensuring that defendants' constitutional rights are prioritized.
What's Next
Following the ruling, the case has been remanded to the post-conviction court for further proceedings consistent with the appellate court's opinion. It remains to be seen whether the state will seek to appeal the decision. Additionally, there may be related cases pending that could also be impacted by this ruling, as the legal community continues to grapple with the implications of nonunanimous jury verdicts.