Through the development of the rule of Teague v. Lane, the Court has ensured that almost no "pro-defendant" ruling will be applied for the benefit of any defendant whose case has become final, marking a significant step toward speeding up the end for the thousands of persons in the United States under a sentence of death. This note concludes that the limiting effects of Teague are two-fold and interrelated. First, Teague has drastically curtailed the ability of the Federal courts to formulate constitutional criminal procedure on review of the constitutional adjudication of State courts. Second, because of the combination of Teague and other habeas procedural rules, more habeas petitioners will have their claims barred from consideration on the merits. Now, even petitioners able to run the gauntlet of the doctrines of procedural default and successive petitioning by emphasizing the doctrines of procedural default and successive petitioning by emphasizing the novelty of their claims are likely to be denied relief precisely because of the novelty of these claims. The end result is that a judiciary more and more critical of increasing "technicality" and the exaltation of form over substance will be making more and more decisions in habeas case based on "procedural technicalities." 362 footnotes