Sunday, November 3, 2013

Teague v. Lane case brief

Teague v. Lane case brief summary
489 U.S. 288 (1989)

Petitioner prisoner was convicted by an all-white jury of attempted murder, armed robbery, and aggravated battery. The United States Court of Appeals for the Seventh Circuit held that the prisoner's fair cross-section argument was procedurally barred, meritless, and could not benefit from a recent Supreme Court decision because that case could not be applied retroactively to cases on collateral review. The prisoner was granted certiorari.

  • The Court took the opportunity to clarify how the question of retroactivity should be resolved for cases on collateral review. 
  • The Court held that the decision of retroactivity should be addressed at the time of the new rule decision. 
  • New constitutional rules of criminal procedure were not retroactively applicable to cases that became final before the decision was announced unless one of two exceptions applied. 
  • A new rule would be applied retroactively if it placed certain kinds of primary, private individual conduct beyond the power of the criminal law-making authority to proscribe, or if it required the observance of those bedrock procedural elements that were absolutely prerequisite to fundamental fairness implicit in the concept of ordered liberty. 
  • Habeas corpus could not be used as a vehicle to create new constitutional rules of criminal procedure unless those rules would be applied retroactively through one of these two exceptions. 
  • Because a decision extending the fair cross-section requirement to the petit jury would not be applied retroactively to cases on collateral review under this approach, the Court refused to address the prisoner's claim.


The judgment of the court of appeals was affirmed.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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