Tatum v. Commissioner of Correction

Summary

The court held that the later constitutional rule governing first-time, in-court eyewitness identifications applies retroactively to the petitioner's collateral challenge because scientific developments, the rule's importance to accurate convictions, and the petitioner's prior litigation of related identification claims satisfied a newly adopted exception to the Teague nonretroactivity framework. It held that the later evidentiary rule permitting expert testimony about eyewitness reliability does not apply retroactively. The court reversed the dismissal of the petitioner's due process and actual innocence claims and remanded for a trial applying the constitutional identification rule retroactively.