Danforth v. Minnesota

Summary

The Supreme Court held that the Teague v. Lane nonretroactivity rule limits the authority of federal courts to grant habeas relief but does not restrict state courts from giving broader retroactive effect to new federal constitutional rules in state postconviction proceedings. The Court concluded that Minnesota was free to apply the confrontation rule announced in Crawford v. Washington more broadly than Teague required. The decision also distinguished federal habeas remedies from state-created remedies for constitutional violations.

Holdings

1. Teague v. Lane does not constrain the authority of state courts to give broader effect to new rules of criminal procedure than Teague requires on federal habeas review.
2. Federal law does not require state courts to apply Crawford v. Washington to cases that were final when Crawford was decided, but federal law also does not prohibit state courts from doing so.
3. Neither Michigan v. Payne nor American Trucking Assns., Inc. v. Smith establishes that federal law limits the relief a state may provide in its own postconviction proceedings.

Questions Presented

1. Whether Teague v. Lane's federal habeas nonretroactivity rule limits the authority of state courts to apply a new federal constitutional rule of criminal procedure more broadly in their own state postconviction proceedings.
2. Whether Michigan v. Payne, American Trucking Assns., Inc. v. Smith, or other federal precedent prohibits a state court from providing relief for a constitutional violation that would not be redressable under Teague on federal habeas review.
3. Whether Crawford v. Washington was required to apply retroactively to Danforth's final state conviction under federal law.

Disposition

reversed_and_remanded