The United States Supreme Court has held that retroactive effect will not be given to a constitutional decision where the newly established doctrine was neither judicially foreshadowed nor enhances the accuracy of criminal trials.
Solem v. Stumes, 104 S. Ct. 1338 (1984).
Theresa C. Homady,
Retroactivity of Constitutional Decisions - Criminal Procedure,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol23/iss3/14