Summary
The Minnesota Supreme Court considers whether the United States Supreme Court's decision in Blakely v. Washington applies retroactively to a conviction that was final before Blakely was decided. The court holds that Blakely announced a new rule of federal constitutional criminal procedure and that the rule is not a watershed rule requiring retroactive application on collateral review. The court affirms the Minnesota Court of Appeals' decision upholding Gerald Houston's sentence.
Topics
Practice areas
Questions Presented
- Whether Blakely v. Washington announced a new rule of federal constitutional criminal procedure for purposes of Teague retroactivity analysis.
- Whether Blakely applies retroactively to a conviction that was final before Blakely was decided.
- Whether Blakely is a watershed rule requiring full retroactive application under the second Teague exception.
Holdings
- Blakely announced a new rule of federal constitutional criminal procedure because reasonable jurists were not compelled by existing precedent to reach its result before Blakely was decided.
- Blakely is a new rule of federal constitutional criminal procedure and is unavailable to defendants whose convictions were final before Blakely was decided and who seek relief on collateral review.
- Blakely is not a watershed rule and therefore does not qualify for the second Teague exception requiring full retroactive application.
Key quotations
“Thus, Blakely is a new rule of constitutional criminal procedure unavailable for collateral use.” (273)
“We therefore hold that, while Blakely is a new rule, it is not a watershed new rule of constitutional criminal procedure.” (274)
Factual background
Gerald E. Houston was convicted of attempted first-degree controlled substance crime and fifth-degree controlled substance crime arising from his possession of items used to manufacture methamphetamine. The district court imposed a 240-month sentence under Minnesota's career-offender statute, a substantial upward departure from the presumptive guidelines sentence of 80.5 months. The departure was based on Houston's prior felony convictions and the finding that the current offense was part of a pattern of criminal behavior.
Procedural history
Houston was convicted in district court and received a 240-month sentence based on an upward durational departure under Minnesota's career-offender statute. The court of appeals affirmed, and the Minnesota Supreme Court denied review. After Houston sought postconviction relief under Neal v. State, the postconviction court upheld the sentence. While his appeal was pending, Blakely was decided; the court of appeals rejected retroactive application of Blakely, and the Minnesota Supreme Court affirmed.