Beard v. Banks
Headline: Death-row inmate’s challenge based on a jury unanimity rule is blocked as the Court limits retroactive application of that new sentencing rule to older federal habeas cases, reducing relief for pre-1988 inmates.
Holding: The rule announced in Mills v. Maryland is a new rule that does not apply retroactively on federal habeas review to convictions that became final before Mills, so the appeals court’s reversal is reversed.
- Pre-1988 death-row inmates generally cannot use Mills in federal habeas challenges.
- Federal judges must perform Teague retroactivity analysis when states raise it.
- State courts’ discretionary review practices do not change finality for federal review.
Summary
Background
A man convicted of 12 first-degree murders in Pennsylvania was sentenced to death and exhausted direct review in 1987. He later argued that jury instructions and the verdict form effectively required juror unanimity before any mitigating factor could be considered, a claim tied to the Court’s 1988 decision in Mills v. Maryland. The Pennsylvania Supreme Court rejected his claim, and a federal appeals court eventually applied Mills retroactively and set aside his death sentence, prompting this Supreme Court review.
Reasoning
The Court applied the three-step Teague framework for rules announced after a conviction becomes final: (1) determine when the conviction became final, (2) ask whether existing precedent compelled the new rule, and (3) if the rule was new, decide whether it fits one of two narrow exceptions. The Court concluded the conviction was final in 1987, that Mills announced a new rule because earlier cases did not compel the focus on individual jurors, and that Mills does not fall within Teague’s exceptions (including the rare “watershed” exception).
Real world impact
Because Mills is a new rule that is not retroactive under Teague, defendants whose convictions became final before Mills cannot obtain relief in federal habeas courts on that ground. Federal judges must perform the Teague analysis in habeas cases, and state practices that sometimes revisit old claims do not change the finality date for federal retroactivity purposes.
Dissents or concurrances
Three Justices dissented, arguing Mills simply applied longstanding Eighth Amendment fairness principles and therefore should be given retroactive effect; they would have upheld the appeals court’s decision and granted relief.
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