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The judicially created revolution in criminal procedure dating from Mapp v. Ohio has thrown off numerous difficult problems of retroactivity. The Supreme Court has recently begun to grapple with these problems,' and commentators, some of whom have long been fascinated by the "conflict of laws in time," have lately turned increasing attention to them.2 One of the most important of the recent articles on this subject is Professor Paul Mishkin's The Supreme Court, 1964 Term Foreword: The High Court, the Great Writ and the Due Process of Time and Law.3 This article, an outgrowth of Professor Mishkin's earlier work on more general retroactivity issues, focuses on the applicability of newly enunciated due process standards to habeas corpus petitions filed by state prisoners whose convictions became final before the date of the enunciating decision. It concludes that unless the newly enunciated constitutional rights affect the reliability of the guilt-determining process, retroactivity should be denied. Professor Mishkin's article is an important one not only because of the great power of the author's analysis, but also because it reflects a

Retroactivity, Reliability, and Due Process: A Reply to Professor Mishkin