Danforth v. Minnesota

PETITIONER: Stephen Danforth
RESPONDENT: Minnesota
LOCATION: Earthquake Park

DOCKET NO.: 06-8273
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: Minnesota Supreme Court

CITATION: 552 US 264 (2008)
GRANTED: May 21, 2007
ARGUED: Oct 31, 2007
DECIDED: Feb 20, 2008

ADVOCATES:
Benjamin J. Butler - on behalf of the Petitioner
Patrick C. Diamond - on behalf of the Respondent

Facts of the case

At Stephen Danforth's trial for sexual abuse of a six-year-old boy, the victim was found incompetent to testify in court, so his videotaped testimony was shown instead. Danforth was convicted and his appeals were unsuccessful. After Danforth's case became final, the Supreme Court ruled in Crawford v. Washington that pre-recorded testimony without the possibility of cross-examination is unconstitutional. Danforth filed a second petition for postconviction relief, seeking to have the Crawford decision applied retroactively to his case. Supreme Court decisions announcing constitutional rules of criminal procedure are applied retroactively only in certain circumstances, which are specified in Teague v. Lane. The state court of appeals declined to retroactively apply Crawford.

On appeal to the Minnesota Supreme Court, Danforth raised an alternative argument, claiming that the state court was free to apply a broader standard of retroactivity than the one in Teague. Under Minnesota state retroactivity principles, Danforth argued, the Crawford case met the criteria for retroactive application. In Danforth's interpretation, the Teague standard was mandatory for federal habeas corpus proceedings but not for state postconviction proceedings. The Minnesota Supreme Court rejected Danforth's arguments, ruling that only U.S. Supreme Court decisions determine the proper standard for retroactive application of constitutional criminal procedure. The Supreme Court subsequently ruled in Whorton v. Bockting that Crawford does not apply retroactively under Teague, but it agreed to consider Danforth's alternative argument.

Question

When determining whether Supreme Court decisions on constitutional rules of criminal procedure apply retroactively, may state supreme courts use state-law retroactivity standards that are broader than the standard in Teague v. Lane?

Media for Danforth v. Minnesota

Audio Transcription for Oral Argument - October 31, 2007 in Danforth v. Minnesota

Audio Transcription for Opinion Announcement - February 20, 2008 in Danforth v. Minnesota

John Paul Stevens:

In the other case I have, Danforth against Minnesota, the case comes to us from the State Supreme Court.

The petitioner is challenging the constitutionality of his 1996 conviction of criminal sexual conduct with a minor.

He contends that allowing the jury to hear a videotape interview with his victim violated the constitutional rule that we later announced in Crawford against Washington.

Generally speaking, new rules of constitutional procedure must be applied in cases that are not yet final when the new rule is announced.

Then under our decision in the case called Teague against Lane, a new rule will not be applied by a federal court in a habeas corpus proceeding that is filed after the state conviction has become final.

The question in this case is whether the Minnesota Supreme Court correctly held that Teague limits the authority of state courts to give broader effect to the rule we announced in Crawford and Teague requires.

We have never suggested that it does.

And for the reasons stated in our opinion filed with the Clerk, we hold that it does not, neither Teague nor any of our other cases explicitly or implicitly constrains the authority of the States to provide remedies for a broader range of constitutional violations, then federal courts must remedy by issuing the writ of habeas corpus.

Accordingly, the judgment of the Supreme Court of Minnesota is reversed, and the case is remanded for further proceedings not inconsistent with this opinion.

The Chief Justice joined by Justice Kennedy has filed a dissenting opinion.