Wainwright v. Sykes

Supreme Court of the United States · 1977 · Federal Courts

Federal CourtsFederal Habeas CorpusState Procedural Defaulthabeas corpusprocedural defaultcause and prejudicecontemporaneous objectionMiranda

Facts

Respondent Sykes was convicted of third-degree murder in Florida. After arrest, he received Miranda warnings, declined counsel, agreed to talk, and made an inculpatory statement that was introduced at trial through police testimony. Although there was testimony that Sykes had consumed alcohol and appeared intoxicated, his lawyer did not object at trial to admission of the statement on the ground that Sykes did not understand the Miranda warnings, and no voluntariness hearing was held. Florida courts later refused to consider that claim on the merits because it had not been timely raised under the state's procedural rule.

Issue

Whether a federal habeas court may review a state prisoner's claim that his statement was admitted in violation of Miranda when the state courts refused to reach the claim because the prisoner failed to comply with a valid state contemporaneous-objection rule. More specifically, the question was whether the Francis v. Henderson cause-and-prejudice standard applies to such a waived objection.

Rule

When a state prisoner fails to comply with a state contemporaneous-objection rule that constitutes an independent and adequate state procedural ground, federal habeas review of the underlying federal claim is barred unless the prisoner shows cause for the default and prejudice resulting from it. Jackson v. Denno does not require a voluntariness hearing absent some contemporaneous challenge to the confession's use.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Ohio, Devin Ortega was convicted of armed robbery. At trial, the prosecution introduced Devin's stationhouse statement; his lawyer did not object, even though there were signs Devin had been heavily medicated when police questioned him. Ohio courts later refused to consider his federal involuntariness claim because he had not complied with the state's contemporaneous-objection rule.

In Devin's later federal habeas petition under 28 U.S.C. § 2254, which is the best answer?

Explanation. When a state court refuses to reach a federal claim because the prisoner failed to comply with a valid state contemporaneous-objection rule, federal habeas review is barred unless the petitioner shows cause and prejudice. The majority rejected the broader deliberate-bypass approach for this setting and applied the cause-and-prejudice standard to waived objections to confessions.