Teague v. Lane, 489 U.S. 288 (1989)
Teague v. Lane is a landmark U.S.
Should the new rule established in Batson v. Kentucky, regarding the discriminatory use of peremptory challenges, be applied retroactively to cases on collateral review?
The rule established in Teague v. Lane is that new constitutional rules of criminal procedure will generally not apply retroactively to cases on federal habeas corpus review unless they fall within two narrow exceptions: (1) if the new rule places certain kinds of primary, private individual conduct beyond the power of criminal law-making authority to proscribe; or (2) if it requires the observance of 'those procedures that are implicit in the concept of ordered liberty.'
The Supreme Court, in a plurality opinion delivered by Justice O'Connor, held that the new rule announced in Batson v. Kentucky was not applicable retroactively on federal habeas corpus review because it did not fall within either of the two narrowly defined exceptions to the general principle of non-retroactivity.
Teague v. Lane is critically significant for law students as it frames the doctrinal approach to retroactivity in habeas corpus jurisprudence. The decision underscores the importance of finality in criminal convictions and provides guidance on the limited scenarios in which new constitutional rules may have retroactive effect. It harmonizes the federal court's role in post-conviction relief and ensures that the state court's final judgments are respected, except in extraordinary circumstances.