Wainwright v. Sykes

Supreme Court of the United States
433 U.S. 72 (1977)

ELI5:

Rule of Law:

A state prisoner who has failed to comply with a state's contemporaneous objection rule at trial must show cause for the procedural default and actual prejudice resulting from the alleged constitutional violation in order to obtain federal habeas corpus review of the defaulted claim.

Facts:

On the evening of January 8, 1972, respondent Sykes told his wife to summon the police because he had just shot Willie Gilbert.
When police arrived at Sykes' trailer home, they found Gilbert dead of a shotgun wound.
Shortly after, Sykes came from across the road and voluntarily told the officers he had shot Gilbert.
Sykes was arrested and taken to the police station, where he was read his Miranda rights.
Sykes declined to seek counsel, indicated a desire to talk, and gave a statement to police.
In his statement, Sykes admitted he had shot Gilbert from the front porch of his trailer home.
Several witnesses, including the police officers, noted that Sykes had been consuming alcohol and appeared to be intoxicated on the day of the shooting.

Procedural Posture:

Sykes was convicted of third-degree murder after a jury trial in the Circuit Court of DeSoto County, Florida, a state trial court.
During the trial, Sykes' counsel did not challenge the admissibility of his post-arrest statements based on an unknowing waiver of Miranda rights.
Sykes appealed his conviction to the Florida state appellate courts but did not raise the issue of the statements' admissibility.
Sykes' subsequent state court petitions for post-conviction relief, which did raise the claim, were denied.
Sykes filed a petition for a writ of habeas corpus in the U.S. District Court for the Middle District of Florida, which granted relief by ordering the state to hold a hearing on the voluntariness of the statements.
Wainwright, the warden, appealed to the U.S. Court of Appeals for the Fifth Circuit.
The Fifth Circuit affirmed the District Court, holding that failure to object at trial only bars federal review where there was a 'deliberate bypass' for tactical reasons.
The U.S. Supreme Court granted certiorari to review the Fifth Circuit's decision.

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Issue:

Does a state prisoner's failure to comply with a state's contemporaneous objection rule at trial bar federal habeas corpus review of a defaulted constitutional claim, absent a showing of cause for the noncompliance and actual prejudice?

Opinions:

Majority - Mr. Justice Rehnquist

Yes. A state prisoner's failure to make a timely objection as required by a state procedural rule precludes federal habeas review unless the petitioner can show both cause for the default and actual prejudice resulting from the alleged constitutional violation. The Court rejects the broader 'deliberate bypass' standard from Fay v. Noia, adopting the stricter 'cause and prejudice' standard from Francis v. Henderson. This standard respects the vital state interests served by contemporaneous objection rules, such as ensuring finality in litigation, allowing for a fresh factual record, and preventing defense counsel from 'sandbagging' by withholding claims in state court. Applying this standard, Sykes advanced no cause for his counsel's failure to object to the confession's admission, and he suffered no actual prejudice, as the other evidence of his guilt was substantial.

Concurring - Mr. Chief Justice Burger

Yes. The 'deliberate bypass' standard of Fay v. Noia was never intended to apply to procedural errors committed during trial. Fay involved a fundamental decision made by the defendant himself—whether to appeal—whereas trial decisions, like whether to object to evidence, are necessarily entrusted to the attorney's on-the-spot tactical judgment. Applying the defendant-centric 'knowing and intelligent waiver' standard to an attorney's conduct during trial is unworkable and illogical. The 'cause and prejudice' standard is the appropriate framework for reviewing such trial-level procedural defaults.

Concurring - Mr. Justice Stevens

Yes. The Court's holding is consistent with how lower federal courts have actually applied the Fay standard, which was often less about a mechanical test and more about the totality of the circumstances. In this case, competent trial counsel could have made a deliberate, tactical decision not to object to the statement. The statement was largely consistent with Sykes' trial testimony, had some mitigating value by suggesting provocation, and would have been admissible for impeachment purposes anyway under Harris v. New York. Given these factors and the overall fairness of the trial, collateral attack is not warranted.

Concurring - Mr. Justice White

Yes, but on narrower grounds. The majority's conclusion that the other evidence of guilt was so substantial as to 'negate any possibility of actual prejudice' is effectively a finding of harmless error, which is sufficient on its own to deny the writ of habeas corpus. The Court did not need to reach the procedural default issue. If it were to be addressed, he believes that counsel's ignorance of a rule could constitute 'cause,' and 'prejudice' should be analyzed under the harmless-error standard, with the burden on the state. However, because Sykes failed to offer any explanation for the default, he concurs in the judgment.

Dissenting - Mr. Justice Brennan

No. The 'deliberate bypass' standard from Fay v. Noia should be retained because the vast majority of procedural defaults stem from attorney error, negligence, or incompetence, not from a deliberate tactical decision. The majority's new 'cause and prejudice' standard is vague and unfairly punishes a defendant for his lawyer's mistake, an error the defendant can neither prevent nor control. This harsh rule effectively insulates potential state constitutional violations from any judicial review. It subordinates fundamental constitutional rights to state procedural rules and undermines the primary role of federal habeas corpus as a guardian of federal rights.

Analysis:

Wainwright v. Sykes marks a significant retrenchment in federal habeas corpus law, substantially limiting access to federal courts for state prisoners. By replacing the petitioner-friendly 'deliberate bypass' standard of Fay v. Noia with the much stricter 'cause and prejudice' test for trial-level procedural defaults, the Court elevated principles of comity, finality, and respect for state procedures. This decision firmly establishes the state trial as the 'main event' for resolving federal constitutional claims and shifts a heavy burden onto petitioners to justify any failure to comply with state rules. The ruling has since made it far more difficult for prisoners to raise claims in federal court that were defaulted due to attorney error, unless that error rises to the level of ineffective assistance of counsel.

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