Brief Fact Summary. Sykes was convicted of murder for shooting and killing Willie Gilbert (“Mr. Gilbert”) in Florida. He made incriminating statements to police, which were admitted during his trial. Sykes did not object to the admission of the statements.
Synopsis of Rule of Law. 28 U.S.C. Section:2254(a) 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.”
At no time during the trial was the admissibility of any of Sykes’ statements challenged by his counsel on the ground that Sykes had not understood the Miranda warnings. The trial judge did not question their admissibility on his own motion or hold a fact-finding hearing on the issue. Sykes appealed his conviction but did not challenge the admissibility of the inculpatory statements. He later filed in the trial court a motion to vacate the conviction and a petition for habeas corpus in the State District Court of Appeals and Supreme Court, which for the first time challenged the statements made to the police on grounds of involuntariness.
Wainwright, on behalf of Florida, challenged the Fifth Circuit decision to order a hearing in state court on the merit’s of Sykes’ contention. The United States Supreme Court (“Supreme Court”) granted certiorari to consider the availability of federal habeas corpus to review a state convict’s claim that testimony was admitted at his trail in violation of his rights under Miranda v. Arizona. The Florida courts refused to consider the issue because of noncompliance with a state contemporaneous-objection rule.
Issue. Can Sykes’ petition be brought under 28 U.S.C. Section:2254(a), which provides that the federal courts shall entertain an application for a writ of habeas corpus “on 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”?
Held. Sykes’ failure to make a 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.
Such a requirement enables the record to be made with respect to the constitutional claim when the recollections of witnesses are freshest and enables the judge who observed the demeanor of those witnesses to make the factual determinations necessary for properly deciding the federal constitutional question.View Full Point of Law
Justice Byron White (“J. White”) concurred with the judgment, but writes to note that the harmless-error rule and deliberate-bypass rule already provide protection of the State’s interest.
Discussion. The Court noted that the Florida law is clear that motions to suppress evidence be raised before trial. Further, the Supreme Court asserted that a state contemporaneous-objection rule should be given respect in order to contribute toward the finality of criminal litigation.