Danforth v. Minnesota

552 U.S. 264 (2008)

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Nature of the Case

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Facts

Danforth (D) was found guilty of first-degree criminal sexual conduct with a minor. The 6-year-old victim did not testify at trial, but the jury saw and heard a videotaped interview of the child. On appeal, D argued that the tape's admission violated the Sixth Amendment's guarantee that 'in all criminal prosecutions, the accused shall enjoy the right ... to be confronted with the witnesses against him.' The Minnesota Court of Appeals concluded that the tape 'was sufficiently reliable to be admitted into evidence,' and affirmed the conviction. The conviction became final in 1998 when the Minnesota Supreme Court denied review and D's time for filing a writ of certiorari elapsed. The Supreme Court then announced a 'new rule' for evaluating the reliability of testimonial statements in criminal cases in Crawford v. Washington. It held that where testimonial statements are at issue, 'the only indicium of reliability sufficient to satisfy constitutional demands is the one the Constitution actually prescribes: confrontation.' D filed a state postconviction petition. Applying the standards set forth in Teague, the Minnesota trial court and the Minnesota Court of Appeals concluded that Crawford did not apply to D's case. The State Supreme Court granted review and held that Teague does not apply to state postconviction proceedings, but concluded that 'we are not free to fashion our own standard of retroactivity for Crawford.' Whorton v. Bockting makes clear that federal law does not require state courts to apply the holding in Crawford to cases that were final when that case was decided. The court granted certiorari to consider whether Teague or any other federal rule of law prohibits them from doing so.