Teague v. Lane

Supreme Court of the United States · 1989 · Criminal Procedure

489 U.S. 288 (1989)

Overruled in part by Edwards v. Vannoy (2021)

Updated July 27, 2026

Criminal ProcedureHabeas CorpusRetroactivityJury Selectioncollateral reviewnew ruleprocedural defaultBatson

Facts

Petitioner, a black man, was convicted by an all-white Illinois jury of attempted murder, armed robbery, and aggravated battery. During jury selection, the prosecutor used all 10 of his peremptory challenges to exclude blacks, and defense counsel twice moved for a mistrial; the trial court denied both motions. On direct appeal petitioner argued a Sixth Amendment fair cross section claim, which the Illinois courts rejected. In federal habeas proceedings he also sought the benefit of Batson and asserted, for the first time, a Swain-based equal protection claim.

Issue

Whether petitioner could obtain habeas relief based on Batson, on an unpresented Swain equal protection claim, or on a proposed extension of the Sixth Amendment fair cross section requirement from the venire to the petit jury. More broadly, the Court addressed what retroactivity standard governs new constitutional rules of criminal procedure on collateral review.

Rule

For cases on collateral review, new constitutional rules of criminal procedure generally do not apply to convictions that were final before the new rules were announced. A case announces a new rule when it breaks new ground or imposes a new obligation on the States or the Federal Government, or, stated differently, when the result was not dictated by precedent existing when the defendant's conviction became final. Two exceptions apply: (1) rules placing certain kinds of primary, private individual conduct beyond the power of the criminal law-making authority to proscribe, and (2) watershed rules of criminal procedure implicating the fundamental fairness and accuracy of the criminal proceeding.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In 2018, Noah Bennett's Ohio robbery conviction became final after his direct appeals ended and the time to seek certiorari expired. In 2022, the Supreme Court announced a new constitutional rule requiring trial judges to give a special limiting instruction before admitting a certain category of prosecution evidence. Noah then filed a federal habeas petition seeking the benefit of that 2022 rule.

Should the federal habeas court apply the 2022 rule to Noah's case?

Explanation. The majority adopted the rule that new constitutional rules of criminal procedure generally do not apply on collateral review to cases already final when the new rule was announced. Finality matters on habeas because of comity and finality concerns. Unless one of the two narrow exceptions applies, Noah cannot obtain the benefit of the 2022 rule.