## Facts

- John Sykes, a Florida state prisoner, was convicted by a jury of third-degree murder for shooting and killing Willie Gilbert at Sykes’s trailer home.
- After police arrived, Sykes stated he had shot Gilbert; at the station he received Miranda warnings, declined counsel, and made inculpatory statements.
- At trial, officers testified about Sykes’s post-Miranda statements; defense counsel did not object to their admission and did not claim Sykes failed to understand the Miranda warnings.
- The trial court did not hold a voluntariness/Miranda hearing on its own initiative, and the conviction was affirmed on direct appeal without any Miranda challenge.
- In later state collateral proceedings, Sykes argued his statements were inadmissible because he did not understand the Miranda warnings; Florida courts declined to reach the claim under a contemporaneous-objection rule requiring suppression motions to be raised before trial.
- In federal habeas proceedings, the district court and the Fifth Circuit concluded Sykes was entitled to a voluntariness-type hearing and treated the state procedural bar as ineffective absent a “deliberate bypass” of the objection.

## Issues

1. Whether a state prisoner’s failure to comply with a state contemporaneous-objection rule bars federal habeas review of a Miranda-based claim.
2. Whether the applicable federal standard is Fay v. Noia’s “deliberate bypass” test or a requirement that the prisoner show “cause” for the default and “actual prejudice” from the alleged constitutional error.
3. Whether due process requires a trial court to conduct a voluntariness/Miranda hearing absent a contemporaneous objection to the confession’s use.

## Decision

- The Supreme Court reversed the Fifth Circuit and held that federal habeas review was barred.
- The Court held that when a state court refuses to consider a federal claim due to an independent and adequate state procedural rule, federal habeas courts may not reach the claim unless the petitioner shows cause for the default and actual prejudice.
- The Court rejected applying Fay v. Noia’s “deliberate bypass” standard in this setting.
- The Court held there is no constitutional requirement for a voluntariness hearing absent a contemporaneous challenge to the confession’s admission.
- Because Sykes did not show cause for failing to object and did not make a sufficient showing of actual prejudice, his Miranda claim could not be reviewed on federal habeas.

## Legal Principles

- A federal habeas court generally will not review a federal constitutional claim defaulted in state court under an independent and adequate state procedural rule.
- To overcome such a procedural default, a state prisoner must show both (1) cause for the failure to comply with the state procedural rule and (2) actual prejudice resulting from the alleged constitutional violation.
- Fay v. Noia’s deliberate-bypass/knowing-waiver approach does not govern review of claims barred by a state contemporaneous-objection rule.
- The Constitution does not require a trial court to hold a voluntariness/Miranda hearing when a confession is admitted unless the defendant contemporaneously challenges its admissibility.

## Conclusion

The Court held that federal habeas courts must respect state contemporaneous-objection rules and may not review a Miranda claim forfeited by failure to object at trial unless the petitioner demonstrates cause for the procedural default and actual prejudice from the alleged error, thereby tightening limits on federal collateral review of state convictions.


Wainwright v. Sykes, 433 U.S. 72 (1977)