Caspari v. Bohlen

1994-02-23

Headline: Court blocks habeas relief by holding that applying double-jeopardy rules to noncapital resentencing would be a new rule, allowing states to retry sentence-enhancement proceedings after procedural errors.

Holding: The Court held that applying the Double Jeopardy Clause to successive noncapital sentence-enhancement proceedings would announce a new rule, so the federal nonretroactivity principle bars habeas relief and the Court of Appeals' grant of relief is reversed.

Real World Impact:

Makes it harder for prisoners to get federal relief when courts announce a new constitutional rule.
Allows states to retry sentence-enhancement proceedings after procedural defects are corrected.
Does not resolve whether double-jeopardy bars noncapital resentencing.

Topics: double jeopardy, sentencing procedures, habeas corpus, state criminal appeals

Summary

Background

A man convicted of three counts of first-degree robbery for a 1981 jewelry store robbery was initially sentenced in Missouri as a “persistent offender” to three consecutive 15-year terms. The state appeals court reversed that sentence because the State had not proved the prior convictions, and the case was sent back for proof and resentencing. On remand the State introduced evidence of four prior felonies and the judge again found persistent-offender status. The federal district court denied the man’s habeas petition, but the Eighth Circuit granted relief, concluding double-jeopardy protections applied to the resentencing.

Reasoning

The Supreme Court examined whether applying the Double Jeopardy Clause to successive noncapital sentence-enhancement proceedings would announce a new constitutional rule that could not be applied to cases final before the rule. The Court concluded that existing precedent did not dictate extending Bullington (a capital-case decision) to ordinary noncapital sentencing, and that reasonable courts had disagreed on the issue. Because giving the man relief would require announcing a new rule, the Court held the federal nonretroactivity rule (Teague) barred habeas relief and reversed the Court of Appeals. The Court expressly did not decide whether double jeopardy actually applies to noncapital resentencing.

Real world impact

The decision leaves the resentencing in this case intact and limits the ability of state prisoners to obtain federal habeas relief based on a constitutional rule announced after their convictions became final. The Court’s ruling is procedural and not a final decision on double-jeopardy protection for noncapital sentences.

Dissents or concurrances

Justice Stevens dissented, arguing the State forfeited the nonretroactivity defense and that Missouri’s persistent-offender hearing is trial-like, so double-jeopardy protection should apply.