William Lee Whittaker, II v. State of Mississippi, 262 So. 3d 531

Defendant William Whittaker was convicted of one count gratification of lust and three counts of sexual battery for sexual abuse of his six‑year‑old daughter; sentences were concurrent multi‑year terms.
After arrest, Whittaker gave a partial recorded interview in which he admitted some touching, denied other allegations, mentioned a prior sex‑offense conviction, and refused a polygraph; a transcript and recording exist.
Defense moved to suppress on narrow grounds challenging the Miranda waiver; at the suppression hearing Whittaker testified but did not claim his confession was induced by promises of treatment.
The trial court admitted a redacted version of the interview recording and transcript at trial; an unredacted version was used at the suppression hearing but not shown to the jury.
On appeal Whittaker argued (1) the confession was involuntary because induced by promises of treatment, and (2) counsel was ineffective for not insisting on redactions of prior‑conviction and polygraph references.
The Supreme Court of Mississippi affirmed, holding the involuntariness claim procedurally barred and the ineffective‑assistance claim without merit because trial exhibits were redacted and the record contradicts appellant’s assertion.

Issue	Whittaker's Argument	State's Argument	Held
Voluntariness of confession	Confession involuntary because officers promised treatment/therapy inducements	Claim was not raised at suppression hearing; record shows no promise claims; thus procedurally defaulted	Procedurally barred; claim not preserved for appeal
Miranda waiver validity	(Related) waiver invalid / confession involuntary	Trial record shows waiver challenged at suppression only on understanding; no promise/threat claim made	No reversible error; waiver challenge preserved but not voluntariness claim
Ineffective assistance — failure to demand redactions	Counsel failed to object to admission of unredacted interview containing prior conviction and polygraph references	Transcript/record show that trial exhibits were redacted; suppression exhibits were unredacted and distinct; counsel presumed competent	Claim fails; record shows redacted versions were used at trial
Record sufficiency / exhibit confusion	Appellate counsel asserts record shows unredacted materials admitted at trial	Clerk supplemented record with originals; exhibit stickers and Bates stamps show which versions were used where	Court finds appellate confusion; no merit to claim

Roberts v. State, 234 So. 3d 1251 (Miss. 2017) (distinguishes voluntariness of Miranda waiver from voluntariness of confession; preservation requirement for coercion claims)
Keller v. State, 138 So. 3d 817 (Miss. 2014) (discusses voluntariness standards for confessions)
Fleming v. State, 604 So. 2d 280 (Miss. 1992) (objection on specific grounds waives other grounds)
Woodham v. State, 779 So. 2d 158 (Miss. 2001) (appellate review requires preservation of specific trial objections)
Johnson v. State, 235 So. 3d 1404 (Miss. 2017) (ineffective‑assistance claims generally reserved for post‑conviction relief unless record fully resolves them)
Swinney v. State, 241 So. 3d 599 (Miss. 2018) (presumption of competent representation; burden on defendant to show ineffectiveness)