Summary
The Supreme Court addressed whether new constitutional rules of criminal procedure should apply retroactively to cases on collateral review. The Court held that the petitioner could not benefit from Batson v. Kentucky, rejected his procedurally defaulted Swain claim, and declined to decide whether the Sixth Amendment fair-cross-section requirement extends to petit juries because that proposed rule would be new and nonretroactive under the framework adopted by the Court.
Topics
Practice areas
Questions Presented
- Whether Batson v. Kentucky applied retroactively to Teague's conviction on collateral review.
- Whether Teague's Equal Protection claim under Swain v. Alabama was procedurally barred because it was not presented to the state courts.
- Whether the Sixth Amendment fair-cross-section requirement extends from the jury venire to the petit jury.
- What retroactivity framework governs new constitutional rules of criminal procedure in cases on collateral review.
Holdings
- Teague could not benefit from Batson v. Kentucky because his conviction became final before Batson was announced and Batson was not retroactive on collateral review.
- Teague's Equal Protection claim under Swain was procedurally barred because he failed to present it to the state courts and did not show cause and prejudice.
- The Court declined to decide whether the Sixth Amendment fair-cross-section requirement extends to the petit jury because any such rule would be new and would not apply retroactively to Teague's collateral-review case.
- New constitutional rules of criminal procedure generally do not apply retroactively to cases that became final before the new rules were announced, except for rules placing primary, private conduct beyond the criminal lawmaking power and watershed rules of criminal procedure implicating fundamental fairness and accuracy.
Key quotations
“Unless they fall within an exception to the general rule, new constitutional rules of criminal procedure will not be applicable to those cases which have become final before the new rules are announced.” (310)
“We therefore hold that, implicit in the retroactivity approach we adopt today, is the principle that habeas corpus cannot be used as a vehicle to create new constitutional rules of criminal procedure unless those rules would be applied retroactively to all defendants on collateral review through one of the two exceptions we have articulated.” (316)
Factual background
Teague, a Black man, was convicted by an all-white Illinois jury. During jury selection, the prosecutor used all ten peremptory challenges to strike Black venire members, while Teague's counsel also struck one Black prospective juror. Teague twice moved for a mistrial, asserting that the prosecutor's strikes denied him a representative jury; the trial court denied both motions after the prosecutor offered a gender-balance explanation.
Procedural history
Teague was convicted in Illinois state court of attempted murder, armed robbery, and aggravated battery by an all-white jury. The Illinois Appellate Court rejected his fair-cross-section claim, the Illinois Supreme Court denied leave to appeal, and the Supreme Court denied certiorari. The federal district court denied habeas relief. The Seventh Circuit initially ruled for Teague, vacated that decision on rehearing en banc, and ultimately affirmed denial of relief, concluding that Batson was not retroactive on collateral review, the Swain claim was procedurally barred, and the fair-cross-section requirement did not extend to petit juries.