Wainwright v. Sykes, 433 U.S. 72 (1977)
A failure to make objections at a criminal trial does not allow a defendant to later challenge the conviction on habeas corpus grounds, when a state has a rule on contemporary objections.
After he was given his Miranda warnings, Sykes confessed to murdering a man, but he was allegedly intoxicated at the time. He failed to raise the issues of whether he had voluntarily waived his Miranda rights and voluntarily made his confession before or during the trial. The state courts that reviewed the conviction on appeal declined to consider these issues because they ruled that Sykes had waived his objections under the contemporary objection rule, which provided that failing to make a proper objection waives any alleged defects.
Sykes brought a habeas corpus petition in a federal court. It was granted on the basis that he had not knowingly and intelligently waived his rights, and the federal court ruled that there was no prejudice to the state. Wainwright, the prison warden, argued on appeal that the federal court should not have disturbed the application of the contemporary objection rule, since it was part of the substantive state law.
- William Hubbs Rehnquist (Author)
- Warren Earl Burger
- Potter Stewart
- Harry Andrew Blackmun
- Lewis Franklin Powell, Jr.
- John Paul Stevens
Before a federal court can make a determination on the merits of a habeas corpus petition, it first must determine whether an independent state ground precludes its review, even if federally cognizable issues are involved. Federal courts historically were not allowed to review habeas petitions if a state court would be prevented from reviewing these issues under state procedural rules, such as the failure to make an objection or file a timely appeal. A failure by a defendant to comply with state substantive law also prevented federal courts from reviewing habeas petitions, notwithstanding the ruling in Fay v. Noia (1963). This decision created the doctrine that a federal court could hold an independent hearing on the issue of whether Miranda rights had been adequately waived, even if this issue could not be raised in a state court under the state's substantive law, as long as there was no prejudice to the state and there had not been a knowing and intelligent waiver of the Miranda rights. However, the principle in Noia should be rejected with regard to situations involving the application of contemporary objection rules. The decision created too broad a rule, and it should not allow federal courts to review habeas petitions based on flaws in state court proceedings, if state law would prevent a state court from reviewing these flaws because the defendant failed to properly and promptly raise them. This decision is limited to situation in which the state court does not reach the issue because it was not properly raised. However, a different result may be reached if there is adequate cause or prejudice, although it is not necessary to define either of those concepts at this time.
- Warren Earl Burger (Author)
Noia was decided on the basis that the defendant was solely responsible for making the choice of whether to waive his constitutional rights. In this situation, the defendant's attorney failed to make the objection promptly and properly, thus making a mistake during the trial process that allowed the confession to be admissible. Courts should be less forgiving of errors by lawyers than errors by defendants.
- John Paul Stevens (Author)
The precedent in Noia concerned only matters involving consent, rather than the trial tactics at issue here. In any case, there was no basis for granting the habeas writ, since the police had properly complied with the Miranda rules.
- William Joseph Brennan, Jr. (Author)
- Thurgood Marshall
The state is not greatly prejudiced by allowing a federal court to review a habeas petition, at least compared to the potential harm that the defendant might suffer if habeas review is withheld. Defense attorneys are unlikely to exploit this process by failing to raise constitutional questions in state court and then bringing them to a federal court to get a second chance at an acquittal or a new trial. They would raise these claims in state court because the case could be immediately dismissed then. The Constitution should prevail in any conflicts with local rules. However, inadvertent errors such as these are not properly covered under the doctrine in Noia, which is based on the deliberate bypass of constitutional rights. The majority also should have defined what it meant by adequate cause or prejudice that might create an exception to the rule in this case.
- Byron Raymond White (Author)
Notwithstanding any state laws in the area, the denial of effective counsel has been held to provide grounds for granting habeas corpus, but the composition of a grand jury does not.
U.S. Supreme CourtWainwright v. Sykes, 433 U.S. 72 (1977)
Wainwright v. Sykes
Argued March 29, 1977
Decided June 23, 1977
433 U.S. 72
During respondent's trial for murder, inculpatory statements made by him to police officers were admitted into evidence. No challenge was made on the ground that respondent had not understood warnings read to him pursuant to Miranda v. Arizona, 384 U. S. 436, nor did the trial judge sua sponte question their admissibility or hold a factfinding hearing. Respondent, who was convicted, did not challenge the admissibility of the statements on appeal, though later he did so, unavailingly, in a motion to vacate the conviction and in state habeas corpus petitions. He then brought this federal habeas corpus action under 28 U.S.C. § 2254, asserting the inadmissibility of his statements by reason of his lack of understanding of the Miranda warnings. The District Court ruled that, under Jackson v. Denno, 378 U. S. 368, respondent had a right to a hearing in the state court on the voluntariness of the statements, and that he had not lost that right by failing to assert his claim at trial or on appeal. The Court of Appeals agreed that respondent was entitled to a Jackson v. Denno hearing, and ruled that respondent's failure to comply with Florida's procedural "contemporaneous objection rule" (which, except as specified, requires a defendant to make a motion to suppress evidence prior to trial) would not bar review of the suppression claim unless the right to object was deliberately bypassed for tactical reasons.
Held: Respondent's failure to make timely objection under the Florida contemporaneous objection rule to the admission of his inculpatory statements, absent a showing of cause for the noncompliance and some showing of actual prejudice, bars federal habeas corpus review of his Miranda claim. Davis v. United States, 411 U. S. 233; Francis v. Henderson, 425 U. S. 536. Pp. 433 U. S. 77-91.
(a) Florida's rule, in unmistakable terms and with specified exceptions, requires that motions to suppress be raised before trial. P. 433 U. S. 85.
(b) There is no constitutional requirement in Jackson v. Denno, supra, or later cases that there be a voluntariness hearing absent some contemporaneous challenge to the use of a confession. P. 433 U. S. 86.
(c) The sweeping language set forth in Fay v. Noia, 372 U. S. 391,
which would render a State's contemporaneous objection rule ineffective to bar review of underlying federal claims in federal habeas corpus proceedings -- absent a "knowing waiver" or a "deliberate bypass" of the right to so object -- is rejected as according too little respect to the state contemporaneous objection rule. Such a rule enables the record to be made with respect to a constitutional claim when witnesses' recollections are freshest; enables the trial judge who observed the demeanor of witnesses to make the factual determinations necessary for properly deciding the federal question; and may, by forcing a trial court decision on the merits of federal constitutional contentions, contribute to the finality of criminal litigation. Conversely, the rule of Fay v. Noia may encourage defense lawyers to take their chances on a verdict of not guilty in a state trial court, intending to raise their constitutional claims in a federal habeas corpus court if their initial gamble fails, and detracts from the perception of the trial of a criminal case as a decisive and portentous event. Pp. 433 U. S. 87-90.
(d) Adoption of the "cause" and "prejudice" test of Francis, while giving greater respect than did Fay to the operation of state contemporaneous objection rules, affords an adequate guarantee that federal habeas corpus courts will not be barred from hearing claims involving an actual miscarriage of justice. The procedural history of this case and the evidence as presented at trial indicate that there exist here neither "cause" nor "prejudice" as are necessary to support federal habeas corpus review of the underlying constitutional contention. Pp. 433 U. S. 90-91.
528 F.2d 522, reversed and remanded.
REHNQUIST, J, delivered the opinion of the Court, in which BURGER, C.J., and STEWART, BLACKMUN, POWELL, and STEVENS, JJ., joined. BURGER, C.J., post, p. 433 U. S. 91, and STEVENS, J., post, p. 433 U. S. 94, filed concurring opinions. WHITE, J., filed an opinion concurring in the judgment, post, p. 433 U. S. 97. BRENNAN, J., filed a dissenting opinion, in which MARSHALL, J., joined, post, p. 433 U. S. 99.