Danforth v. Minnesota
552 U.S. ___ (2008)

Annotate this Case

SYLLABUS
OCTOBER TERM, 2007
DANFORTH V. MINNESOTA


SUPREME COURT OF THE UNITED STATES

DANFORTH v. MINNESOTA

certiorari to the supreme court of minnesota

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 under 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. Pp. 4–27.

   (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 product of its own views about sound policy, Crawford, 541 U. S., at 67. Pp. 4–6.

   (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 constitutional 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). Pp. 6–11.

   (c) Neither Linkletter nor Teague explicitly or implicitly constrained the States’ authority to provide remedies for a broader range of constitutional violations than are redressable on federal habeas. And Teague makes clear that its rule was tailored to the federal habeas context and thus had no bearing on whether States could provide broader relief in their own postconviction proceedings. Nothing in Justice O’Connor’s general nonretroactivity rule discussion in Teague asserts or even intimates that her definition of the class eligible for relief under a new rule should inhibit the authority of a state agency or state court to extend a new rule’s benefit to a broader class than she defined. Her opinion also clearly indicates that Teague’sgeneral nonretroactivity rule was an exercise of this Court’s power to interpret the federal habeas statute. Since Teague is based on statutory authority that extends only to federal courts applying a federal statute, it cannot be read as imposing a binding obligation on state courts. The opinion’s text and reasoning also illustrate that the rule was meant to apply only to federal courts considering habeas petitions challenging state-court criminal convictions. The federal interest in uniformity in the application of federal law does not outweigh the general principle that States are independent sovereigns with plenary authority to make and enforce their own laws as long as they do not infringe on federal constitutional guarantees. The Teague rule was intended to limit federal courts’ authority to overturn state convictions not to limit a state court’s authority to grant relief for violations of new constitutional law rules when reviewing its own State’s convictions. Subsequent cases confirm this view. See, e.g., Beard v. Banks, 542 U. S. 406, 412. Pp. 11–18.

   (d) Neither Michigan v. Payne, 412 U. S. 47, nor American Trucking Assns., Inc. v. Smith, 496 U. S. 167, cast doubt on the state courts’ authority to provide broader remedies for federal constitutional violations than mandated by Teague. Pp. 18–24.

   (e) No federal rule, either implicitly announced in Teague, or in some other source of federal law, prohibits States from giving broader retroactive effect to new rules of criminal procedure. Pp. 24–26.

718 N. W. 2d 451, reversed and remanded.

   Stevens, J., delivered the opinion of the Court, in which Scalia, Souter, Thomas, Ginsburg, Breyer, and Alito, JJ., joined. Roberts, C. J., filed a dissenting opinion in which Kennedy, J., joined.

Official Supreme Court caselaw is only found in the print version of the United States Reports. Justia caselaw is provided for general informational purposes only, and may not reflect current legal developments, verdicts or settlements. We make no warranties or guarantees about the accuracy, completeness, or adequacy of the information contained on this site or information linked to from this site. Please check official sources.