Thank You For Submiting Feedback!
The limitation on federal habeas relief is not jurisdictional in nature, but rests on prudential concerns counseling against the application of the U.S. Const. amend. IV exclusionary rule on collateral review. The court simply concludes that the costs of applying the exclusionary rule on collateral reviews outweigh any potential advantage to be gained by applying it there.
Police officers investigating a double murder in Michigan brought respondent Williams to a police station for questioning. When respondent denied any involvement in the murders, an officer told him that he could either give them the truth or they would charge him and lock him up. Respondent then admitted furnishing the murder weapon to the killer, who had called respondent after the crime and told him where the weapon and other incriminating items had been discarded. The officers then advised respondent of his Miranda rights for the first time; but he waived those rights and made further inculpatory statements. The respondent, charged with murder and unlawful possession of a firearm, moved before trial to suppress his responses to interrogation; but a Michigan trial court declined to suppress the above statements on the ground that respondent had been given a timely warning of his Miranda rights. After the respondent was convicted and his conviction was upheld on direct appeal, the respondent petitioned a Federal District Court for a writ of habeas corpus and alleged a violation of his Miranda rights as the principal ground for relief. The District Court, granting relief, not only found that respondent had been placed in custody when the police threatened to lock him up, and that therefore all statements made between that point and the time that he was advised of his Miranda rights ought to have been excluded; but also concluded -- although neither the respondent nor the prison warden who was opposing the petition had addressed the issue -- that the respondent’s statements made after the Miranda warning had been involuntary and therefore suppressible under the due process clause of the Federal Constitution's Fourteenth Amendment. The United States Court of Appeals for the Sixth Circuit, in affirming, summarily rejected an argument that the Stone v. Powell rule ought to apply to bar review of the respondent's Miranda claim. Petitioner sought review of the decision.
The Court held that Stone's restriction on the exercise of federal habeas jurisdiction did not extend to a state prisoner's claim that his conviction rests on statements obtained in violation of the Miranda safeguards. According to the Court, the Stone rule was not jurisdictional in nature, but was based on prudential concerns counseling against applying the Fourth Amendment exclusionary rule of Mapp v. Ohio, 367 U.S. 643, 6 L. Ed. 2d 1081, 81 S. Ct. 1684, on collateral review. The Court held that eliminating review of Miranda claims would not significantly benefit the federal courts in their exercise of habeas jurisdiction, or advance the cause of federalism in any substantial way. The burdens placed on busy federal courts would not be lightened, since it was reasonable to suppose that virtually every barred Miranda claim would simply be recast as a due process claim that the particular conviction rested on an involuntary confession. However, the Court held that the district court erred in considering the involuntariness of the statements respondent made after receiving the Miranda warnings. The habeas petition raised no independent due process claim, and the record was devoid of any indication that petitioner consented under Federal Rule of Civil Procedure 15(b) to the determination of such a claim.