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Teague v. Lane

Law Dictionary

Law Dictionary

Featuring Black's Law Dictionary 2nd Ed.
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Criminal Procedure keyed to Saltzburg

Citation. Teague v. Lane, 489 U.S. 288, 109 S. Ct. 1060, 103 L. Ed. 2d 334, 1989 U.S. LEXIS 1043, 57 U.S.L.W. 4233 (U.S. Feb. 22, 1989)

Brief Fact Summary. The petitioner, Teague (the “petitioner”ť) was convicted in an Illinois state court of attempted murder and other offenses. The prosecutor used all ten of his peremptory challenges to exclude blacks from the jury. The petitioner twice unsuccessfully moved for a mistrial arguing that he was entitled to a jury of his peers.

Synopsis of Rule of Law. An individual may not seek to enforce a new rule of law in federal habeas corpus proceedings if the new rule was announced after the petitioner’s conviction became final, or if the petitioner is seeking to establish a wholly new rule or to apply a settled precedent in a novel way that would result in the creation of a new rule.

Facts. The petitioner, a black man, was convicted in an Illinois state court for three counts of attempted murder, two counts of armed robbery, and one count of aggravated battery by an all white jury. During jury selection, the prosecutor used all ten of his peremptory challenges to exclude blacks. The petitioner’s attorney used one of his ten challenges to exclude a black woman married to a police officer. The petitioner’s attorney moved for a mistrial after six blacks were struck, but the trial court denied the motion. Teague again moved for a mistrial after an additional four blacks were struck. The prosecutor defended the challenges by stating that he was trying to achieve a balance of men and women on the jury. The trial court again denied the motion.
The petitioner appealed to the Illinois Appellate Court which rejected his claim that the challenges denied him the right to be tried by a jury representative of the community. The petitioner then filed a petition for writ of habeas corpus in United States District Court (“District Court”ť) again arguing the fair cross section claim, and arguing that under Swain v. Alabama, a prosecutor could be questioned about his use of peremptory challenges once he volunteered an explanation. The District Court denied the Petitioner’s petition, but a panel of the Court of Appeals agreed that the fair cross section requirement applied to a petit jury, and held that there was a prima facie case of discrimination. The Court of Appeals voted to rehear the case, but postponed it until a decision in Batson v. Kentucky, which overruled a portion of Swain. After Batson was decided, the Court of Appeals held that the petitioner could not benefit from the rule retroactively, that his Swain claim was proc
edurally barred, and the fair cross section claim was limited to jury venire.

Issue. Is the petitioner prevented from benefiting from the rule in Batson since his conviction became final before Batson was decided?
Is the petitioner procedurally barred from raising the Equal Protection Clause claim under Swain since he did not raise the claim at trial or on direct appeal?

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