Teague v. Lane
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The Supreme Courts of Florida and the Alaska Court of Appeals also chose broader state retroactivity frameworks instead of Teague. All 321 flagged citations have now been read; the other opinions applied Teague, reported the adverse acts of Danforth or Edwards, or used nearby treatment language for unrelated authorities and party arguments.
6,041 later cases cite Teague v. Lane; 321 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Teague v. Lane?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Overruled in Part
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The Court eliminated Teague's watershed-rule exception, leaving new procedural rules unavailable retroactively on federal collateral review.
Edwards v. Vannoy · Supreme Court of the United States · filed
The purported watershed exception is moribund. Third, on that last point, the dissent responds that Teague nominally identified a retroactivity exception for watershed procedural rules and that we should do so as well.
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Declined to Follow
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The Florida Supreme Court retained its broader Witt retroactivity analysis instead of adopting Teague for state postconviction review.
Johnson v. State · Supreme Court of Florida · filed
We continue to apply our longstanding Witt analysis, which provides more expansive retroactivity standards than those adopted in Teague.
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The Alaska Court of Appeals held that Teague does not bind state courts and applied Alaska's own retroactivity test.
Smart v. State · Alaska Court of Appeals · filed
For these reasons, we reject the State's contention that we are bound by federal law to apply the Teague retroactivity test when we decide whether Blakely's expansion of the Sixth Amendment right to jury trial should be applied retroactively. Rather, we conclude that the Teague retroactivity test binds federal courts, not state courts.
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The Florida Supreme Court again applied Witt and described Teague as a much narrower framework with different factors.
Asay v. State · Supreme Court of Florida · filed
In addressing whether Ring should apply retroactively, this Court announced in Johnson that despite the federal courts’ use of Teague v. Lane, 489 U.S. 288 (1989), to determine retroactivity, this Court would “continue to apply our longstanding Witt14 analysis, which provides more expansive retroactivity standards than those adopted in Teague.” Johnson, 904 So. 2d at 409 (emphasis added).15
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Limited
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The Court held that Teague's nonretroactivity rule does not limit state courts reviewing their own convictions from giving new procedural rules broader effect.
Danforth v. Minnesota · Supreme Court of the United States · filed
federal habeas, but does not in any way limit the authority of a state court, when reviewing its own state criminal convictions, to provide a remedy for a violation that is deemed “nonretroactive” under Teague.
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