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Keywords

precedentappealtrialmotioninterrogation

precedentappealinterrogation

Related Cases

Butler v. McKellar, 494 U.S. 407, 110 S.Ct. 1212, 108 L.Ed.2d 347, 58 USLW 4294

Facts

Six weeks after Pamela Lane was murdered, petitioner Butler was arrested on an unrelated assault charge. While in custody, he was informed that he was a suspect in Lane's murder. After receiving Miranda warnings, Butler signed waiver forms and made incriminating statements during interrogation. His motion to suppress these statements was denied at trial, leading to his conviction and death sentence. After his conviction became final, Butler filed a federal habeas petition, which was dismissed by the District Court and affirmed by the Court of Appeals.

Issue

Whether the new rule established in Arizona v. Roberson, which bars police-initiated interrogation after a suspect requests counsel, applies retroactively to Butler's case on collateral review.

Rule

A new decision generally is not applicable in cases on collateral review unless it was dictated by precedent existing at the time the petitioner's conviction became final, with two narrow exceptions for certain types of rules.

Analysis

The Court determined that the ruling in Roberson was a new rule because it was not dictated by existing precedent at the time Butler's conviction became final. The Court also found that Roberson's rule did not fall within either of the exceptions for retroactive application on collateral review, as it did not place certain conduct beyond the power of the law or require procedures essential to an accurate conviction.

The Court determined that the ruling in Roberson was a new rule because it was not dictated by existing precedent at the time Butler's conviction became final.

Conclusion

The Supreme Court affirmed the judgment of the Court of Appeals, concluding that Butler was not entitled to the retroactive benefit of the Roberson decision.

Who won?

The State prevailed in the case, as the Supreme Court affirmed the lower court's dismissal of Butler's habeas petition, reasoning that the new rule established in Roberson was not applicable to his case.

The State prevailed in the case, as the Supreme Court affirmed the lower court's dismissal of Butler's habeas petition.

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Keywords

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