Withrow v. Williams

Police officers took Robert Allen Williams, Jr. (defendant) from his home to the police station for questioning about a murder. Forty minutes into the questioning, after Williams had already implicated himself in the crime, officers advised Williams of his Miranda rights. Williams waived his rights and made further inculpatory statements. The State of Michigan (plaintiff) charged Williams with murder. Williams moved to suppress his statements to the officers, but the trial court denied the motion, finding that the officers’ Miranda warnings were timely. Williams was convicted, and his conviction was affirmed on appeal. Williams subsequently filed a federal habeas corpus petition alleging the violation of his Miranda rights. The district court granted a writ of habeas corpus, and the appellate court affirmed. The state petitioned the United States Supreme Court for certiorari, arguing that federal habeas review was not available for Williams’s claim that his conviction was based on statements obtained in violation of Miranda. The state’s argument was based on Stone v. Powell, 428 U.S. 465 (1976), in which the Supreme Court had held that if a prisoner had a full and fair opportunity to litigate a Fourth Amendment claim in state court, federal habeas review was unavailable for the prisoner’s claim that his conviction was based on evidence obtained in an unconstitutional search or seizure. The Supreme Court granted certiorari to determine if Stone’s holding extended to the Miranda context.