USD School of Law professor Chris Hutton cited in Supreme Court ruling

VERMILLION, S.D. -- University of South Dakota School of Law Professor Chris Hutton received supreme credit for an Alabama Law Review article, “Retroactivity in the States: The Impact of Teague v. Lane on State Postconviction Remedies,” she authored in 1993.

When the United States Supreme Court handed down five decisions last week, including a reversal of the Minnesota Supreme Court’s verdict that state courts are not bound by the U.S. Supreme Court’s case law that restricts the retroactive application of newly developed principles of criminal procedures, one of the Court’s decisions that was authored by Associate Justice John Paul Stevens cited and included quotes from Hutton’s article on the subject.

"Commentators were similarly confident that Teague’s 'restrictions appl[ied] only to federal habeas cases,' leaving States free to 'determine whether to follow the federal courts' rulings on retroactivity or to fashion rules which respond to the unique concerns of that state.' Hutton, Retroactivity in the States: The Impact of Teague of Teague v. Lane on State Postconviction Remedies, 44 Ala. L. Rev. 421, 423-424, 422-423 (1993)," stated the Court’s 7-2 majority opinion, which means states may act in a broader fashion when reviewing their own retroactive criminal convictions.

Hutton received a bachelor’s degree from St. Joseph’s College, juris doctor from Washburn University and a master’s of law degree from Harvard University. A member of the bar in South Dakota and Kansas, Hutton teaches courses in criminal law, criminal procedure, advanced criminal procedure and evidence at The U.

For more information about Hutton and the USD School of Law, please go to To read more information about the Supreme Court’s significant decision, including the mention of Hutton’s article, visit this link