Danforth v. Minnesota

In a key criminal procedure case, the Supreme Court held that states may apply its pro-criminal cases retroactively in post-conviction appeals even if the Court holds that federal courts may apply them only prospectively.

At issue is whether Stephen Danforth may appeal his Minnesota conviction for sexual abuse of a six-year-old boy based on videotaped testimony. At Danforth's trial, the victim was found incompetent to testify in court, so he told his story on videotape. 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.

On Feb. 20, a divided Supreme Court sided with Danforth, sending the case back to the Minnesota Supreme Court. “States are independent sovereigns with plenary authority to make and enforce their own laws as long as they do not infringe on federal constitutional guarantees,” Justice John Paul Stevens wrote for the 7-2 majority. “While we have ample authority to control the administration of justice in the federal courts — particularly in their enforcement of federal legislation — we have no comparable supervisory authority over the work of state judges.”

In a strongly-worded dissent joined by Justice Anthony Kennedy, Chief Justice John Roberts invoked the Framers’ intent and Marbury v. Madison, noting: “the court’s opinion invites just the sort of disuniformity in federal law that the Supremacy Clause was meant to prevent.”

Question presented: Whether state courts have the authority to expand retroactivity of Supreme Court criminal procedure rulings.