Peter Luurtsema v. Commissioner of Correction

Summary

The court held that its later, narrower interpretation of the kidnapping statute applies retroactively in state habeas proceedings to convictions that became final before that interpretation was issued. It adopted a general presumption favoring full retroactivity for judicial decisions narrowing substantive criminal liability, while recognizing limited exceptions where relief would not correct a gross miscarriage of justice. The court further held that the presumption applies to the petitioner's conviction because his kidnapping sentence was based on restraint allegedly incidental to assault, and the underlying assault and attempted sexual assault convictions remain valid.