Teague v. Lane
Headline: Jury selection and habeas review limited as Court narrows when new criminal‑procedure rules apply on collateral review, blocking retroactive relief for people with final convictions and leaving jury‑fairness questions unresolved.
Holding: The Court adopts Justice Harlan's retroactivity approach for collateral habeas cases, declines retroactive application of Batson to this final conviction, finds the Swain claim procedurally barred, and affirms the court of appeals.
- Makes it harder for final convictions to get new rules applied on federal habeas.
- Prevents retroactive use of Batson for convictions already final.
- Leaves whether petit juries must mirror the community undecided.
Summary
Background
A Black man was convicted by an all‑white Illinois jury after the prosecutor used his peremptory strikes to exclude Black venirepersons. The defendant’s trial lawyer moved twice for a mistrial; the trial court denied those motions. The state courts rejected his fair‑cross‑section claim, and he later filed a federal habeas corpus challenge (a federal review filed after state appeals finish).
Reasoning
The Court adopted Justice Harlan’s approach for retroactivity in collateral habeas cases: new constitutional rules generally do not apply to convictions that were final before the rule was announced. The Court held that Batson’s new burden‑shifting rule could not be applied retroactively to this final conviction. It also found the Swain‑based equal‑protection claim procedurally barred because it was not raised in state court. Because extending the fair‑cross‑section rule to petit juries would be a new rule and would not be applied retroactively under that approach, the Court declined to decide whether the Sixth Amendment requires petit‑jury composition changes.
Real world impact
As a practical matter, people whose convictions were final before a new Supreme Court criminal‑procedure rule announced later will usually not get that rule on federal habeas. Petitioners with final convictions cannot rely on Batson here, and the question whether petit juries must reflect a community cross‑section remains for future cases.
Dissents or concurrances
Justice Brennan (joined by Justice Marshall) dissented, warning the plurality sharply restricts federal habeas review and should have reached the merits; several Justices filed separate concurring opinions limiting or qualifying parts of the judgment.
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