Chambers v. State
2013 Minn. LEXIS 313
| Minn. | 2013Background
- Chambers was convicted by a Rice County jury of first-degree murder and related offenses for a 1996 shooting that killed a deputy sheriff.
- He was sentenced to life imprisonment without the possibility of release under Minnesota law, a mandatory result for his offense given the statute then in effect.
- On direct appeal, the court affirmed the conviction and the life sentence as not violating the Eighth Amendment.
- Chambers later filed a series of postconviction petitions, with the second petition arguing Miller/Graham-based Eighth Amendment challenges and asserting a retroactive effect under Minn. Stat. § 590.01, subd. 4(b)(3).
- The postconviction court denied relief as untimely under Minn. Stat. § 590.01, subd. 4(a), and the court held Miller did not apply retroactively under Teague.
- The Supreme Court of Minnesota affirmed, holding Miller does not apply retroactively and the petition was untimely; the court did not hold a hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Graham retroactivity applies to Chambers’ petition | Chambers relies on Graham’s framework for juvenile sentences. | State contends Graham is inapplicable to Chambers’ juvenile homicide case and Teague controls retroactivity. | Graham not retroactively applicable to Chambers |
| Whether Miller applies retroactively under Teague | Miller cannot be retroactive because it constrains sentencing approaches for juveniles. | State argues Miller is not retroactive under Teague (new rule not watershed). | Miller is a new rule and not retroactive under Teague (majority view) |
| Whether Miller is substantive or procedural for Teague analysis | Miller should be substantive because it prohibits a certain punishment for a class of defendants. | State argues Miller is procedural because it affects how punishment is determined, not the punishment itself. | Miller deemed procedural by majority; not retroactive under Teague |
| Whether Miller constitutes a watershed rule justifying retroactivity | Miller could be watershed due to fundamental fairness concerns. | No watershed status; Miller does not alter bedrock procedural elements. | Miller not watershed; no retroactive relief |
| Whether Teague should govern retroactivity or Minnesota’s own approach | Danforth III allows state courts to apply broader retroactivity principles beyond Teague. | Teague governs retroactivity in Minnesota postconviction, as adopted. | Teague governs retroactivity; Miller not retroactive in this case |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (2010) (juveniles have diminished culpability; life without parole for nonhomicide offenses)
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (mandatory life without parole for juveniles violates Eighth Amendment; requires individualized consideration)
- Teague v. Lane, 489 U.S. 288 (1989) (retroactivity framework for new constitutional rules)
- Danforth v. Minnesota, 552 U.S. 264 (2008) (limits Teague applicability on state collateral review; later decisions constrain/overrule)
- Campos v. State, 816 N.W.2d 480 (Minn. 2012) (applies Teague retroactivity framework in Minnesota, addressing retroactivity of new rules)
- Ring v. Arizona, 536 U.S. 584 (2002) (Sixth Amendment jury-determination requirement for aggravating factors in death penalty cases)
- Schriro v. Summerlin, 542 U.S. 348 (2004) (substantive vs procedural classification of new sentencing rules under Teague)