Experimental. Doctrines is a new Annlex feature, starting with four areas: Self-incrimination, Brady, Terry and Miranda. Each page collects what courts have said about a leading case, quoted from the opinions that cite it. Annlex Chat uses these collections to help find relevant cases; what a case holds still comes from its opinion. We'd like to hear what's useful, missing or wrong: Send feedback
Stone v. Powell bar inapplicable to Miranda claims on federal habeas
Leading case
Withrow v. Williams, 507 U.S. 680 (1993)
How courts have described it
holding that Stone does not apply to a state prisoner’s claim that his conviction rests on statements obtained in violation of the safeguards set out in Miranda v. Arizona, 384 U. S. 436 (1966)
Reed v. Farley, 512 U.S. 339 (1994)
refusing to extend Stone to Miranda claims raised on habeas; stating that “ ‘[prophylactic’ though it may be, in protecting a defendant’s Fifth Amendment privilege against self-incrimination, Miranda safeguards a fundamental trial right”
Jerry Lee Staley v. Kurt Jones, 239 F.3d 769 (6th Cir. 2001)
contrasting Mapp and Miranda rules, and allowing habeas attack in the latter instance because the reliability of the conviction is implicated by a Miranda violation but not a Mapp violation
United States v. Clawson, 842 F. Supp. 428 (D. Or. 1994)
distinguishing Miranda violation from Fourth Amendment violation for purposes of habeas corpus review based on its different purposes
People v. Trujillo, 49 P.3d 316 (Colo. 2002)
commenting that “[prophylactic though it may be, in protecting a defendant’s ... privilege against self-incrimination, Miranda safeguards a ‘fundamental trial right’”
State v. Walton, 41 S.W.3d 75 (Tenn. 2001)
commenting that "[p]rophylactic though it may be, in protecting a defendant's . . . privilege against self-incrimination, Miranda safeguards a `fundamental trial right'"
State v. Walton, 41 S.W.3d 75 (Tenn. 2001)
About this page
The quotations above are from court opinions that cite the leading case, in each court's own words. The heading is a short label Annlex generated from those quotations. It has not been reviewed by a lawyer and is not legal advice.