Does the rule of Enmund, or is it a "watershed rule of criminal procedure" comparable to Gideon v. Wainwright or Saffle v. Saffle?

MultiRegion, United States of America

The following excerpt is from Greenawalt v. Ricketts, 943 F.2d 1020 (9th Cir. 1991):

The second exception clearly does not apply. The rule of Enmund, whatever its significance, is not a "watershed rule of criminal procedure" comparable to Gideon v. Wainwright, 372 U.S. 335, 83 S.Ct. 792, 9 L.Ed.2d 799 (1963), the case most often cited in connection with this second exception. Saffle, 110 S.Ct. at 1264.

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