SCOTUS Reverses Sixth Circuit in Howes v. Fields
The Supreme Court reversed the Sixth Circuit Court of Appeals in a Miranda-based case this week, ruling that the government doesn’t have to read Miranda rights to prisoners during jailhouse interrogations about crimes unrelated to their current incarceration.
The decision tossed the Sixth Circuit’s categorical rule that a prisoner questioned in private about events occurring outside the prison is the subject of a custodial interrogation under Miranda v. Arizona.
In the case, Howes v. Fields, sheriff's deputies questioned Michigan prisoner Randall Fields about allegations that he had engaged in sexual conduct with a 12-year-old boy before coming to prison. Fields was neither given Miranda warnings nor advised that he did not have to speak with the deputies. Fields confessed to the crime during the interrogation, and later moved to suppress his confession. Fields' motion was denied, and he was convicted.
A federal district court subsequently granted Fields' habeas petition in the matter; the Sixth Circuit Court of Appeals affirmed, holding that the interview in the conference room was a "custodial interrogation" within the meaning of Miranda because isolation from the general prison population combined with questioning about conduct occurring outside the prison makes any such interrogation custodial per se.
The appellate court reasoned that the Supreme Court clearly established in Mathis v. United States that "Miranda warnings must be administered when law enforcement officers remove an inmate from the general prison population and interrogate him regarding criminal conduct that took place outside the jail or prison."
Justice Alito, who authored the unanimous opinion, rejected the appellate court's categorical rule, writing, "In this case, it is abundantly clear that our precedents do not clearly establish the categorical rule ... that the questioning of a prisoner is always custodial when the prisoner is removed from the general prison population and questioned about events that occurred outside the prison. On the contrary, we have repeatedly declined to adopt any categorical rule with respect to whether the questioning of a prison inmate is custodial."
The Court reasoned that the five-to-seven interrogation was not a custodial interrogation because deputies told Fields more than once that he was free to leave and return to his cell, and Fields was unrestrained. The Supreme Court also noted that Fields states several times during the interview that he no longer wanted to talk to the deputies, but he didn't ask to return to his cell.
- February's First Four: SCOTUS Decides Kawashima, More (FindLaw's Supreme Court blog)
- Howes v. Fields (FindLaw's CaseLaw)
- Prison Inmates and Miranda (Crime & Consequences)
- Judicial Proceedings and Custodial Interrogation (FindLaw)
- The Supreme Court Holds That Responding to Police Interrogation Waives The Right to Remain Silent (FindLaw)
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