Barajas v. United States, No. 16-1680 (8th Cir. 2017)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of a 28 U.S.C. 2255 petition, holding that the district court correctly found that Teague v. Lane, 489 U.S. 288 (1989), barred the application of the Supreme Court's decision in Padilla v. Kentucky, 559 U.S. 356 (2010). Given the importance of protecting the finality of criminal convictions, the court joined its sister circuits and held that the Teague limit on retroactivity applies to collateral review of both state and federal convictions. The court also held that Teague's bar applied to federal petitioners raising ineffective assistance of counsel claims.
Court Description: Gruender, Author, with Smith, Chief Judge, and Wollman, Circuit Judge] Prisoner case - Habeas. The district court did not err in determining Teague v. Lane, 489 U.S. 228 (1989), bars the application of the Supreme Court's decision in Padilla v. Kentucky, 559 U.S. 356 (2010). The court joins other circuits in determining the Teague limit on retroactivity applies to collateral review of both federal and state convictions; Teague's bar applies to federal petitioners raising ineffective assistance of counsel claims.
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