Danforth v. Minnesota

Summary

The Supreme Court held that the Teague rule, which limits the retroactive application of new constitutional criminal-procedure rules in federal habeas proceedings, does not restrict state courts from providing broader retroactive remedies in their own post-conviction proceedings. The Court concluded that Minnesota was free to apply the rule announced in Crawford v. Washington to convictions that became final before Crawford was decided, even though federal law did not require that result.

Holdings

1. Teague's rule of nonretroactivity limits the availability of relief in federal habeas proceedings but does not constrain a state court's authority to provide a remedy for a new federal constitutional rule in its own postconviction proceedings.
2. No federal rule identified in the case prohibits state courts from adopting and applying broader state-law retroactivity standards in their own postconviction proceedings.

Questions Presented

1. Whether Teague v. Lane limits the authority of state courts to give broader retroactive effect in state postconviction proceedings to a new federal constitutional rule of criminal procedure than federal habeas law requires.
2. Whether any other federal rule of law prohibits state courts from providing such broader relief.

Disposition

reversed_and_remanded