Wainwright V Sykes

433 U.S. 72 (1977)

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Nature of the Case

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Facts

Sykes (D) was convicted of third-degree murder. D told his wife to summon the police because he had just shot Willie Gilbert. When the police arrived at D's trailer home, they found Gilbert dead of a shotgun wound, lying a few feet from the front porch. Shortly after their arrival, D came from across the road and volunteered that he had shot Gilbert, and a few minutes later D's wife approached the police and told them the same thing. D was immediately arrested and taken to the police station. D was read his Miranda rights, and declined to seek the aid of counsel and indicated a desire to talk. D then made a statement that he had shot Gilbert from the front porch of his trailer home. At no time during the trial was the admissibility of any of D's statements challenged by his counsel on the ground that D had not understood the Miranda warnings. Nor did the trial judge sua sponte question their admissibility or hold a factfinding hearing bearing on that issue. D appealed his conviction but did not challenge the admissibility of the inculpatory statements. Eventually in his petitions for habeas corpus, D, for the first time, challenged the statements made to police on grounds of involuntariness. D was unsuccessful. D initiated the present action under 28 U.S.C. § 2254, asserting the inadmissibility of his statements by reason of his lack of understanding of the Miranda warnings. It held that Jackson v. Denno requires a hearing in a state criminal trial prior to the admission of an inculpatory out-of-court statement by the defendant. It held that D had not lost his right to assert such a claim by failing to object at trial or on direct appeal since only 'exceptional circumstances' of 'strategic decisions at trial' can create such a bar to raising federal constitutional claims in a federal habeas action. The court stayed issuance of the writ to allow the state court to hold a hearing on the 'voluntariness' of the statements. Wainwright (P), the warden, appealed this decision to the United States Court of Appeals for the Fifth Circuit. That court concluded that the failure to comply with the state rule requiring objection at the trial would only bar review of the suppression claim where the right to object was deliberately bypassed for reasons relating to trial tactics. The court affirmed the District Court order that the State hold a hearing on whether D knowingly waived his Miranda rights at the time he made the statements. The Supreme Court granted certiorari.