Teague v. Lane generally precludes the retroactive application of new constitutional rules of criminal procedure to collateral review of criminal convictions. When federal courts reviewing state convictions apply this rule, it has a certain amount of logic: it protects society’s interest in federalism and finality. But courts apply this rule to cases in myriad procedural postures, even when the forces motivating Teague are not present. This Note will examine three scenarios where Teague has been blindly invoked. It will then explain why this blind invocation is not only theoretically but also practically problematic, and it will suggest a solution (or a start of a solution) to the problem.