Teague v. Lane
489 U.S. 288 (1989)
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Rule of Law:
A new constitutional rule of criminal procedure will not be applied retroactively to cases on collateral review unless the new rule either places certain kinds of primary, private individual conduct beyond the power of the criminal law to proscribe, or it requires the observance of watershed procedural rules that are implicit in the concept of ordered liberty and essential to the fundamental fairness and accuracy of a trial.
Facts:
- Petitioner Teague, a black man, was tried in Illinois.
- During jury selection, the prosecutor used all ten of his peremptory challenges to exclude black individuals from the jury pool.
- Teague's counsel moved for a mistrial, arguing that Teague was entitled to a jury of his peers.
- The prosecutor defended the challenges, stating he was trying to achieve a balance of men and women on the jury.
- The trial court denied the mistrial motions.
- An all-white jury convicted Teague of attempted murder, armed robbery, and aggravated battery.
Procedural Posture:
- Teague was convicted in an Illinois state trial court after the court denied his motions for a mistrial based on the prosecutor's use of peremptory strikes.
- Teague, as appellant, appealed to the Illinois Appellate Court, which affirmed his conviction.
- The Illinois Supreme Court denied leave to appeal, and the U.S. Supreme Court denied certiorari, making his conviction final.
- Teague filed a petition for a writ of habeas corpus in the U.S. District Court for the Northern District of Illinois, which denied the petition.
- Teague, as appellant, appealed to the U.S. Court of Appeals for the Seventh Circuit.
- A panel of the Seventh Circuit reversed, but the court granted rehearing en banc, which vacated the panel's opinion.
- The en banc Seventh Circuit, with Teague as appellant and Lane as appellee, affirmed the district court's denial of the writ.
- The U.S. Supreme Court granted certiorari to review the judgment of the Seventh Circuit.
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Issue:
Must a new constitutional rule of criminal procedure, which has been announced after a defendant's conviction became final, be applied retroactively to that defendant's case on collateral review?
Opinions:
Majority - Justice O’Connor
No. New constitutional rules of criminal procedure generally do not apply retroactively to cases on collateral review once a conviction has become final. The Court adopts Justice Harlan's approach to retroactivity, prioritizing the interests of comity and finality in criminal proceedings. The purpose of federal habeas corpus is to ensure that a state conviction was constitutional under the law existing at the time the conviction became final, not to endlessly re-litigate cases based on later-developed legal principles. A 'new rule' is one where the result was not dictated by precedent at the time the conviction became final. Such new rules will only apply retroactively on collateral review if they fall into one of two narrow exceptions: (1) the rule places certain primary, private conduct beyond the state's power to criminalize, or (2) the rule announces a 'watershed' procedural protection without which the likelihood of an accurate conviction is seriously diminished. The rule Teague asks for—extending the fair cross-section requirement to the petit jury—would be a new rule and does not fit either exception. Therefore, the Court declines to reach the merits of his claim.
Concurrence - Justice White
Concurs in the judgment. Although he previously disagreed with the Court's decisions to apply new rules retroactively to all cases on direct review, he accepts those decisions as precedent. In light of those cases, adopting a different standard of general non-retroactivity for cases on collateral review is an acceptable and logical application of the Court's evolving retroactivity jurisprudence.
Concurrence - Justice Stevens
Concurs in the judgment. He agrees with adopting Justice Harlan's general approach to retroactivity for habeas cases but disagrees with the plurality's modification of the second exception to require a link to factual innocence, preferring Harlan's original 'fundamental fairness' standard. Although he believes Teague's Sixth Amendment claim has merit and implicates fundamental fairness, he feels constrained by the Court's holding in Allen v. Hardy, which found the similar Batson rule non-retroactive on collateral review. Since the fairness concerns are identical, he agrees that Teague cannot obtain relief.
Concurrence - Justice Blackmun
Concurs in the judgment. He joins the part of Justice Stevens' concurrence which finds that Teague has alleged a meritorious Sixth Amendment violation but that retroactivity principles prevent granting him relief.
Dissenting - Justice Brennan
Yes. The plurality's new, restrictive approach to habeas corpus is an unprecedented departure from decades of precedent that should not have been adopted without full briefing and argument. The decision abandons stare decisis and drastically curtails the Great Writ, which historically provided a broad federal forum to remedy any constitutional violation. The two exceptions created by the plurality are so narrow they will prevent federal courts from addressing a wide variety of important constitutional claims, thus allowing unconstitutional convictions to stand. It is better to correct an injustice for one petitioner, even if others are not helped, than to ignore the injustice entirely.
Analysis:
This case dramatically altered the landscape of federal habeas corpus review for state prisoners. By establishing this new framework for retroactivity, the Teague Court created a significant barrier to prisoners seeking to benefit from new constitutional rules of criminal procedure. The decision prioritizes the principles of finality and comity over the evolution of constitutional law on collateral review, effectively preventing federal courts from announcing and applying most new rules in habeas cases. Consequently, the primary avenue for developing new constitutional protections in criminal procedure has been restricted to direct review, fundamentally changing the role and power of the federal writ of habeas corpus.
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