The Supreme Court decided today that the rule of Ramos v. Louisiana, 590 U.S. ___ (2020)--that a state jury must be unanimous to convict a criminal defendant of a serious offense--is a new rule of criminal procedure and, as such, it does not apply retroactively to cases on federal collateral review. Edwards v. Vannoy, 593 U.S. ___ (May 17, 2021). The "watershed" rule exception to retroactivity of new procedural rules discussed in Teague has never been found to apply and is expressly eliminated.