Supreme Court of the United States

Caspari v. Bohlen

February 23, 1994510 U.S. 383

Summary

The Supreme Court reversed the Eighth Circuit's direction to grant habeas relief to Christopher Bohlen, holding that extending the Double Jeopardy Clause's Bullington protection to successive noncapital sentence-enhancement proceedings would announce a 'new rule' of constitutional law under Teague v. Lane, because no precedent existing at Bohlen's January 2, 1986 finality date dictated that result and neither Teague exception applied. The Court first confirmed that the State's Teague argument was fairly included in the question presented, then expressly declined to decide whether the Double Jeopardy Clause actually applies to noncapital sentencing or whether Missouri's persistent-offender scheme is sufficiently trial-like. Justice Stevens dissented, contending the State forfeited its Teague defense under Rule 14.1(a) and that the persistent-offender hearing is the practical equivalent of a trial protected by the Double Jeopardy Clause.

Holding

  • Whether the Teague nonretroactivity issue raised by the State was fairly included in the question presented in the petition for certiorari.. Yes. Because the State argued Teague in its petition, in the courts below, and in its merits brief, and the Teague question is a necessary predicate (a subsidiary question) to resolving the question presented, the Court properly considers it notwithstanding Rule 14.1(a).
  • Whether applying the Double Jeopardy Clause to successive noncapital sentence-enhancement proceedings, as the Eighth Circuit did by extending Bullington, announced a new rule of constitutional law under Teague.. Yes. At the time respondent's conviction and sentence became final (January 2, 1986), a reasonable jurist would not have considered the application of the Double Jeopardy Clause to noncapital sentencing dictated by existing precedent; the Court of Appeals therefore erred in directing the District Court to grant the writ.
  • Whether either of the two narrow exceptions to the Teague nonretroactivity principle applies to a double jeopardy bar on successive noncapital sentencing.. No. Imposing such a bar would not place primary, private individual conduct beyond the reach of the criminal law-making power, because respondent remains subject to imprisonment on each conviction regardless of persistent-offender status; nor is it a watershed rule implicating fundamental fairness and accuracy.

Docket 92-1500

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