Supreme Court of the United States · 2008 · Federal Courts
Federal CourtsRetroactivityState postconviction reviewHabeas corpusTeagueretroactivityfederal habeasstate courts
Facts
A Minnesota jury convicted Stephen Danforth in 1996 of first-degree criminal sexual conduct with a minor. The 6-year-old victim did not testify, but the jury saw and heard a videotaped interview, and the Minnesota Court of Appeals affirmed the conviction under Ohio v. Roberts; the conviction became final in 1998. In 2004, the Supreme Court decided Crawford v. Washington, announcing a new rule for testimonial statements. Danforth then sought state postconviction relief, arguing that admission of the videotape violated Crawford.
Issue
Does Teague v. Lane, or any other federal rule of law, prohibit state courts from giving broader retroactive effect in their own state postconviction proceedings to new federal constitutional rules of criminal procedure than federal habeas courts must give under Teague?
Rule
Teague's nonretroactivity rule limits the availability of relief in federal habeas proceedings for state prisoners, but it does not constrain state courts reviewing their own state convictions in state postconviction proceedings from providing broader remedies for violations of new federal constitutional rules of criminal procedure.
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In Ohio, Malik Turner was convicted in state court, and his conviction became final in 2014. In 2024, the Supreme Court announced a new federal constitutional rule of criminal procedure that would not be retroactive on federal habeas under Teague. On state postconviction review, the Ohio Supreme Court decides to apply the new rule to final Ohio convictions as a matter of state remedial policy.
Is the Ohio Supreme Court prohibited by federal law from giving the new rule that broader effect?
Explanation. The majority held that Teague's nonretroactivity principle is a limit on federal habeas relief for state prisoners, not a binding rule restricting state courts in state postconviction review of their own convictions. A state may therefore provide broader remedies for violations of new federal constitutional rules than federal habeas courts may provide. The Court specifically rejected the idea that Teague or some free-floating federal interest in uniformity bars that choice.