WAINWRIGHT v. SYKES 433 U.S. 72 (1977)

In Sykes the adequate state ground bar to federal habeas corpus, buried in fay v. noia (1963), was unearthed and returned to service with little more than a coat of paint for disguise. Noia had held that a state prisoner was not barred from seeking federal habeas corpus relief merely because the applicant had failed to raise his or her federal constitutional claim in the earlier state proceeding as required by state law. Noia was attacked within the Supreme Court and by some scholars for sacrificing finality of decision. State judges trumpeted their resentment at giving federal district courts the last word in the state criminal process.

Sykes was the culmination of the attack on Noia from within the Court. A state prisoner sought federal habeas corpus, arguing that his rights to a warning under miranda v. arizona (1966) had been violated when his statement was admitted into evidence at his state trial. He had not objected when the evidence was offered, as state law required. The Supreme Court held, 7–2, that federal habeas corpus was barred.

Justice william h. rehnquist, for the majority, announced that failure to raise a federal constitutional claim in the manner required by state law bars resort to federal habeas corpus unless the applicant shows "cause" for the procedural default and "prejudice" from the forfeiture of the federal claim. Defendant had asserted no cause for the absence of timely objection, and prejudice was negated by other evidence of his guilt, independent of his statement.

Kenneth L. Karst
(1986)