US Supreme Court: Questioning of a Prison Inmate Does Not, By Itself, Trigger Miranda Warnings

Taking a prisoner aside for questioning does not necessarily convert a noncustodial situation to one in which Miranda applies. Howes v. Fields, 2012 WL 538280 (S. Ct. 2012).

Summary: The US Supreme Court reversed a Sixth Circuit decision to grant an inmate habeas corpus relief from his convictions for third-degree criminal sexual conduct. The inmate had argued that while he was in prison he was taken away for an interrogation regarding his criminal activities conducted before he was in prison, but he did not receive any Miranda warnings. The Supreme Court rejected the Sixth Circuit’s rationale that Miranda rights categorically apply when an inmate is removed from the general prison populace to be questioned on activities that occurred outside of prison that is unrelated to his current incarceration. Turning to the facts and circumstances surrounding the interrogation, the Supreme Court majority, led by Justice Alito, held that the inmate’s interrogation was not custodial in nature.

Discussion: Randall Lee Fields, a Michigan state prisoner, was escorted from his prison cell by a corrections officer to a conference room where he was questioned by two sheriff’s deputies about criminal activity he had allegedly engaged in before coming to prison, specifically that he had engaged in sexual conduct with a twelve year old boy. At no time was Fields given Miranda warnings or advised that he did not have to speak with the deputies.

As relevant here: Fields was questioned for between five and seven hours; Fields was told more than once that he was free to leave and return to his cell; the deputies were armed, but Fields remained free of restraints; the conference room door was sometimes open and sometimes shut; several times during the interview Fields stated that he no longer wanted to talk to the deputies, but he did not ask to go back to his cell; and after Fields confessed and the interview concluded, he had to wait an additional 20 minutes for an escort and returned to his cell well after the hour when he generally retired.

Implications: Neither the Supreme Court nor the SJC enforce the Sixth Circuit’s categorical rule that a prisoner is automatically in custody for the purposes of Miranda application. Instead, for both courts, in determining whether a person is in custody for purposes of triggering Miranda, the initial step is to ascertain whether, in light of the objective circumstances of the interrogation, a reasonable person would have felt he or she was not at liberty to terminate the interrogation and leave. This so-called freedom-of-movement test is a necessary but not a sufficient condition for determining whether a person is in custody. Counsels for criminal defendants facing similar situation should not only satisfy the freedom-of-movement test, but also look to facts of other cases to establish a distinction between their case and that of Fields.

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