Criminal Procedure keyed to Kamisar
Wainwright v. Sykes
Sykes was convicted of third-degree murder after a jury trial in the Circuit Court of DeSoto County, Florida. On the evening of January 8, 1972, Sykes told his wife to call police because he had just shot Mr. Gilbert. When police arrived at Sykes’ trailer home, police found Mr. Gilbert dead of a shotgun wound. Shortly after their arrival, Sykes approached police and volunteered that he had shot Mr. Gilbert. Sykes’ wife confirmed his story. Sykes was arrested and taken to the police station. Once there, he was read his Miranda rights and declined to have an attorney. He then admitted to shooting Mr. Gilbert from the front porch of his trailer home. This evidence was admitted at trial through the testimony of the two officers who heard it. 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.
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