Danforth v. Minnesota, 552 U.S. 264 (2008)
Primary Holding
State courts are not constrained by the Teague rule and may provide broader retroactive effect to new rules of criminal procedure than is required by federal law.
In the case of Danforth v. Minnesota, the Supreme Court decided that state courts can give more lenient treatment to new rules about criminal procedures than what federal law requires. This matters because it allows state courts to potentially help people who were convicted under old rules that may not be fair anymore. If someone is facing a criminal case and believes their rights weren't properly protected, this ruling means they might have a better chance of getting a new trial or having their case reviewed more favorably in state court.
AI-generated plain-language summary to help you understand this case
In 1996, Stephen Danforth was convicted by a Minnesota jury of first-degree criminal sexual conduct involving a minor, specifically a 6-year-old victim. The child did not testify at the trial; however, the jury was presented with a videotaped interview of her, which Danforth argued violated his Sixth Amendment right to confront witnesses against him. The Minnesota Court of Appeals upheld the conviction, determining that the videotape was sufficiently reliable for admission into evidence based on the precedent set in *Ohio v. Roberts*. Danforth's conviction was finalized in 1998 after the Minnesota Supreme Court denied further review. After his conviction became final, the U.S. Supreme Court issued a new ruling in *Crawford v. Washington* (2004), which established that testimonial statements must be subject to confrontation to satisfy constitutional requirements. Following this, Danforth filed a state postconviction petition, claiming that the admission of the videotape violated the new rule established in *Crawford*. The Minnesota trial court and Court of Appeals ruled that *Crawford* did not apply retroactively to his case under the standards set forth in *Teague v. Lane*. The Minnesota Supreme Court later reviewed the case, considering whether *Crawford* should apply retroactively and whether state courts could adopt a broader retroactivity standard than that of *Teague*, ultimately rejecting both arguments. The case raised significant questions regarding the retroactive application of new constitutional rules and the authority of state courts to provide broader interpretations than those mandated by the U.S. Supreme Court. The Supreme Court's decision in this case clarified that *Teague* does not restrict state courts from giving greater effect to new rules of criminal procedure than required by federal law.
Whether the Teague rule constrains the authority of state courts to give broader effect to new rules of criminal procedure than is required by that opinion.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- October 31, 2007
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Stevens
- Damages Awarded
- N/A
- Data Quality
- high
Cunningham v. California, 549 U.S. 270 (2007)
Consumer WonThe California determinate sentencing law violates a defendant's right to a jury trial under the Sixth and Fourteenth Amendments by allowing a judge to impose a sentence above the statutory maximum based on facts not found by a jury or admitted by the defendant.
Rice v. Collins, 546 U.S. 333 (2006)
Consumer LostA federal court must defer to reasonable state-court determinations of fact in a habeas corpus case and cannot set aside those determinations based on its own interpretations of the record.
Bell v. Thompson, 545 U.S. 794 (2005)
Consumer LostThe Court of Appeals abused its discretion by withholding its mandate for more than five months after the denial of certiorari without entering a formal order.
Oregon v. Guzek, 546 U.S. 517 (2006)
Consumer LostThe State may constitutionally limit the innocence-related evidence that a defendant can introduce at a new sentencing proceeding to only that evidence presented at the original trial.