Sunday, November 3, 2013

Wainwright v. Sykes case brief

Wainwright v. Sykes case brief summary
433 U.S. 72 (1977)

Petitioner warden sought review of the decision of the United States Court of Appeals for the Fifth Circuit, which had affirmed respondent prisoner's habeas corpus action, 28 U.S.C.S. § 2254, alleging that his inculpatory statements admitted at his trial were in violation of his Miranda rights because he did not understand the warnings.

The prisoner had been convicted of third-degree murder in the Florida state court. He never challenged the admissibility of the inculpatory statements he made after being arrested. The prisoner brought this habeas corpus action asserting the inadmissibility of his statement to the police officers claiming that he did not understand his Miranda warnings. The lower courts found that the prisoner was entitled to a hearing in a state criminal trial prior to admitting inculpatory out-of-court statements.

  • The court reversed and accepted the state's position that the statute required the prisoner to raise before trial the motion to suppress his testimony. 
  • The court held that failure to timely object before trial to the admission of the inculpatory statements amounted to an independent and adequate state procedural ground which would prevent direct review by habeas corpus, absent a showing of cause and prejudice attendant to a state procedural waiver.


The court reversed the judgment and remanded to the district court with instructions to dismiss the petition for a writ of habeas corpus.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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