In 1991, their creation was ruled to be state action in Edmonson v Leesville Concrete, and in 1972's Johnson v Louisiana, the Supreme Court refused to apply to the states a federal requirement that they be unanimous

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1. In 1991, their creation was ruled to be state action in Edmonson v Leesville Concrete, and in 1972's Johnson v Louisiana, the Supreme Court refused to apply to the states a federal requirement that they be unanimous