The United States Supreme Court decided Ramos v. Louisiana in 2020, requiring all states to convict criminal defendants by a unanimous jury. However, this case only applied to petitioners on direct, and not collateral, appeal. In this thesis, I argue that the Ramos precedent should apply to people on collateral appeal as well, exploring the implications of such a decision and the criteria that should be used to make the decision in the case before the court, Edwards v. Vannoy (2021). Ultimately, I find that because the criteria currently used to determine retroactivity of new criminal precedents does not provide a clear answer to the question posed in Edwards, the Court should give more weight to the defendant's freedoms pursuant to the presumption of innocence while considering the potential for any disastrous outcomes.

Jane Austen’s depictions of musical performers and listeners in her novels suggest her belief that musical performances should strengthen intimacy between people, both between listeners and performers as well as among listeners. Austen commends music for its power to increase intimacy through honest expressions of taste, which more often arise in private performances, but she warns against its power to decrease intimacy through pretentious displays of taste, which more often arise in public performances. Austen’s belief that music allows for this healthy intimacy indicates that music has great significance in society. Austen suggests that music has a greater importance to everyday life than many may originally suppose, as it is a universal connection between people. Ultimately, Jane Austen’s perspective of music’s great power both to expose pretentiousness and to cultivate intimacy should lead all of her readers to recognize and respect music’s true power and to consider seriously the importance and role of music in their own lives.