What are the implications of a new set of federal criminal rules that apply retroactively to criminal cases on direct review?

4 New rules apply retroactively to criminal cases on direct review. Griffith v. Kentucky, 479 U.S. 314, 328, 107 S.Ct. 708, 716, 93 L.Ed.2d 649 (1987).

1 This is in contrast to United States v. North, 746 F.2d 627 (9th Cir.1984), cert. denied, 470 U.S. 1058, 105 S.Ct. 1773, 84 L.Ed.2d 832 (1985), which Mkhsian overruled, where the defendant and the undercover agent engaged in five separate drug transactions: the government didn't charge on the first, the jury acquitted on the second, and the defendant was found guilty for the latter three.