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Keywords

defendantappealhearingtrialmotionhabeas corpusobjectionrespondentadmissibility
defendantappealhearingtrialhabeas corpusobjectionrespondentadmissibility

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Wainwright v. Sykes, 433 U.S. 72, 97 S.Ct. 2497, 53 L.Ed.2d 594

Facts

Respondent Sykes was convicted of third-degree murder after making inculpatory statements to police, which were admitted into evidence without objection. He did not challenge the admissibility of these statements during his trial or on appeal, although he later filed motions in state court claiming the statements were inadmissible due to his lack of understanding of the Miranda warnings. The District Court ruled that he was entitled to a hearing on the voluntariness of the statements, but the Court of Appeals affirmed this decision, leading to the Supreme Court's review.

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, 86 S.Ct. 1602, 16 L.Ed.2d 694; nor did the trial judge sua sponte question their admissibility or hold a factfinding hearing.

Issue

Whether a defendant has a right to a hearing on the voluntariness of a confession when he has not objected to its admission at trial, and whether federal habeas review is available despite a state procedural waiver.

The simple legal question before the Court calls for a construction of the language of 28 U.S.C. s 2254(a), which provides that the federal courts shall entertain an application for a writ of habeas corpus 'in behalf of a person in custody pursuant to the judgment of a state court only on the ground that he is in custody in violation of the Constitution or laws or treaties of the United States.'

Rule

A defendant does not have a right to a hearing on the voluntariness of a confession if he does not object to its admission at trial, and federal habeas review is barred unless there is a showing of 'cause' and 'prejudice' for the failure to comply with state procedural rules.

We therefore conclude that Florida procedure did, consistently with the United States Constitution, require that respondents' confession be challenged at trial or not at all, and thus his failure to timely object to its admission amounted to an independent and adequate state procedural ground which would have prevented direct review here.

Analysis

The Supreme Court applied the rule that a defendant's failure to object to the admission of a confession at trial constitutes a waiver of the right to challenge its voluntariness in federal habeas proceedings. The Court emphasized that the Florida contemporaneous-objection rule requires that such objections be made at trial, and without a timely objection, the defendant cannot later claim that the confession was involuntary. The Court found that Sykes had not shown cause for his failure to object or any actual prejudice resulting from the admission of his statements.

The Court emphasized that the Florida contemporaneous-objection rule requires that such objections be made at trial, and without a timely objection, the defendant cannot later claim that the confession was involuntary.

Conclusion

The Supreme Court reversed the decision of the lower courts and remanded with instructions to dismiss the petition for federal habeas corpus relief.

The Supreme Court reversed the decision of the lower courts and remanded with instructions to dismiss the petition for federal habeas corpus relief.

Who won?

Wainwright, on behalf of the State of Florida, prevailed because the Supreme Court upheld the application of the state procedural rule barring federal review of the confession's admissibility due to the lack of a timely objection.

Petitioner Wainwright, on behalf of the State of Florida, here challenges a decision of the Court of Appeals for the Fifth Circuit ordering a hearing in state court on the merits of respondent's contention.

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