Danforth v. Minnesota

At Stephen Danforth's trial for sexual abuse of a six-year-old boy, the victim was found incompetent to testify in court, so his videotaped testimony was shown instead. 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.