## Facts

- Horace Butler, held in custody on an assault charge for which he had counsel, was questioned by police about an unrelated murder.
- Police gave Butler Miranda warnings; he signed written waivers and made incriminating statements about the murder.
- The trial court denied Butler’s motion to suppress the statements; he was convicted of capital murder and sentenced to death.
- Butler’s conviction became final before the Supreme Court decided Arizona v. Roberson (1988).
- Roberson held that, under Miranda and Edwards v. Arizona, police may not initiate interrogation about a separate offense after a suspect requests counsel.
- Butler sought federal habeas relief arguing Roberson should apply retroactively because it merely applied Edwards to different facts.

## Issues

1. Whether Arizona v. Roberson announced a “new rule” under Teague v. Lane, making it unavailable on federal habeas review for convictions final before Roberson.
2. If Roberson was a new rule, whether it fell within either Teague exception (substantive rules or “watershed” procedural rules).

## Decision

- The Supreme Court affirmed the denial of federal habeas relief.
- The Court held Roberson announced a “new rule” because its result was not dictated by precedent when Butler’s conviction became final.
- The Court relied on substantial pre-Roberson lower-court disagreement about whether Edwards barred police-initiated questioning on a different offense.
- The Court held neither Teague exception applied: Roberson was procedural (not substantive) and not a “watershed” rule essential to accuracy.
- Because Roberson was not retroactive on collateral review, Butler was not entitled to suppression of his statements on that basis.

## Legal Principles

- Under Teague, a rule is “new” if it was not dictated by existing precedent when the conviction became final; new rules generally do not apply retroactively on federal habeas review.
- A court’s characterization of a decision as “controlled” by earlier precedent does not resolve whether it is a “new rule” for Teague purposes.
- Significant disagreement among reasonable jurists before the later decision supports finding the later decision was not dictated by existing precedent.
- Teague exceptions are narrow: (1) substantive rules limiting the state’s power to punish, and (2) “watershed” procedural rules necessary to fundamental fairness and accuracy.
- Prophylactic interrogation restraints associated with Miranda/Edwards-type doctrines are unlikely to qualify as “watershed” rules for retroactivity.

## Conclusion

The Court held that Roberson expanded Edwards in a way not dictated by prior precedent, making it a “new rule” under Teague; because it was neither substantive nor a watershed procedural rule, it did not apply retroactively to Butler’s already-final conviction on federal habeas review.


Butler v. McKellar, 494 U.S. 407 (1990)