U.S. Supreme Court: Danforth v. Minnesota

Decision Date: February 20, 2008:

No. 06-8273. Argued October 31, 2007-Decided February 20, 2008
After this Court announced a “new rule” for evaluating the reliability of testimonial statements in criminal cases, see Crawford v. Washington, 541 U. S. 36, 68-69, petitioner sought state postconviction relief, arguing that he was entitled to a new trial because admitting the victim’s taped interview at his trial violated Crawford’s rule.

The Minnesota trial and appeals courts concluded that Crawford did not apply retroactively nder Teague v. Lane, 489 U. S. 288. The State Supreme Court agreed, and also concluded that state courts are not free to give a decision of this Court announcing a new constitutional rule of criminal procedure broader retroactive application than that given by this Court.

Held: Teague does not constrain the authority of state courts to give broader effect to new rules of criminal procedure than is required by that opinion.

(a) Crawford announced a “new rule”-as defined by Teague-because its result “was not dictated by precedent existing at the time the defendant’s conviction became final,” Teague, 489 U. S., at 301 (plurality opinion). It was not, however, a rule “of [this Court’s] own devising” or the roduct of its own views about sound policy, Crawford, 541 U. S., at 67.

(b) The Court first adopted a “retroactivity” standard in Linkletter v. Walker, 381 U. S. 618, 629, but later rejected that standard for cases pending on direct review, Griffith v. Kentucky, 479 U. S. 314, and on federal habeas review, Teague v. Lane, 489 U. S. 288. Under Teague, new onstitutional rules of criminal procedure may not be applied retroactively to cases on federal habeas review unless they place certain primary individual conduct beyond the States’ power to proscribe or are “watershed” rules of criminal procedure. Id., at 310 (plurality opinion). .

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Danforth v. Minnesota 06-8273

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