Danforth was convicted of first-degree criminal sexual conduct in Minnesota state court. Danforth was convicted for sexually abusing J.S., a 6-year-old boy, who was found incompetent to testify at trial. However, a videotaped interview of J.S. was admitted into evidence on trial. The court of appeals affirmed Danforth’s conviction. Alleging various trial errors, Danforth filed a petition for post conviction relief, which was denied in 2001.
After the Supreme Court’s decisions in Crawford v. Washington, Danforth filed a second petition for post conviction relief alleging he was entitled to relief based on the rules established by Crawford, that testamentary evidence in the form of a video tape can only be entered into evidence if the defendant had the opportunity to confront, or cross-examine, the witness. The post conviction court denied Danforth's petition, finding that Crawford did not apply retroactively to Danforth’s case; the court of appeals affirmed. In Teague v. Lane, the Supreme Court held that its decisions do not apply retroactively to state decisions if they announce a new rule of constitutional criminal procedure.
On further appeal, Danforth argued that the Minnesota Supreme Court is free to apply a broader retroactivity standard than that in Teague and that he is entitled to the benefit of Crawford under state retroactivity principles. The Minnesota Supreme Court rejected his argument, ruling that it was compelled to apply Teague even in state proceedings. It further held that Teague announced a new rule of constitutional criminal procedure, but not a "watershed" rule, and therefore that the rule in Crawford does not apply retroactively.
1. Are state supreme courts required to use the standard announced in Teague v. Lane, 489 U.S. 288 (1989), to determine whether United States Supreme Court decisions apply retroactively to state-court criminal cases, or may a state court apply state-law- or state-constitution-based retroactivity tests that afford application of Supreme Court decisions to a broader class of criminal defendants than the class defined by Teague?
2. Did Crawford v. Washington, 541 U.S. 36 (2004), announce a “new rule of constitutional criminal procedure,” as Teague defines that phrase and, if it did, was it a watershed rule of procedure subject to full retroactive application?
Supreme Court Opinion