The Federal District Court for the Eastern District of New York has held that O'Callahan v. Parker, a decision concerning subject-matter jurisdiction, must be applied retroactively.
Flemings v. Chafee, 330 F. Supp. 193 (E.D. N.Y. 1971).
Thomas C. Black,
Criminal Law - Subject-Matter Jurisdiction - Retroactivity,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol10/iss3/10