Chapter 10 Update 10.10
Howes, Warden v. Fields
Significance of the Case : Custody for Miranda purposes may not exist where police interrogate a prisoner serving time in a prison when an interrogation involves questions concerning crime outside of the prison, where the prisoner is free to return to his cell at any time, and has been repeatedly advised of that fact, with a prisoner was not handcuffed but the officers were armed and where the Miranda warnings were not offered before the prisoner made inculpatory statements.
Howes, Warden v. Fields
Supreme Court of the United States
___U.S. ___, 2012 U.S. LEXIS 1077 (2012).
While serving time in a Michigan prison, Randall fields was taken to a conference room where two police officers questioned him concerning allegations that he had engaged in sexual activity with a 12-year-old male. Mr. fields arrived at the interrogation around escorted by correctional officials and outside police officers questioned him about the alleged sexual activity for between five and seven hours. Although he was not read his Miranda warnings, at the beginning of the interview he was told that he was free to leave and that he would be returned to his cell at any time. He was not handcuffed; the conference door was open sometimes and closed other times; and the officers were armed. During the interrogation he was also told that he could leave whenever he wished. Although Mr. fields became agitated at some point during the interview, he eventually confessed to engaging in sexual activities with the young male. During the course of the interview, Mr. fields contended that he noted that he no longer wanted to talk to the deputies but he never asked to go back to his cell until the deputies concluded their interview with him. At no time during the encounter was he ever given to the Miranda warnings. Mr. Fields' confession to police was admitted at his sex crimes trial as substantive evidence.
A Michigan trial court convicted Mr. fields of criminal sexual contact with a young boy. This conviction occurred despite his objection that his Miranda rights had been violated by the interrogation process that occurred within his prison. The Michigan Court of Appeals affirmed his conviction and the Michigan Supreme denied discretionary review. A Michigan federal district court granted his petition for habeas corpus based on the alleged Miranda violation and the Sixth Circuit Court of Appeals affirmed the trial court reversal of his conviction on the ground that the conference from interrogation qualified as custodial interrogation under the principles of Miranda because interrogation occurring away from the general prison population with questions concerning conduct outside the prison makes any interrogation custodial by itself. The Supreme Court granted certiorari to consider whether, under the facts of this case, Mr. fields was in custody for Miranda purposes.
Procedural Issue :
Where a prisoner in is removed from the general prison population and taken to an interrogation room that is isolated from other prisoners and where this individual is subject to questions by armed police concerning conduct that occurred outside of the place of custody, and where the prisoner has been informed that he was free to return to his usual cell at any time, is such interrogation considered custodial for Miranda purposes?
We granted certiorari. 562 U.S. ___, 131 S. Ct. 1047, 178 L. Ed. 2d 862 (2011) .
Under [federal law], a federal court may grant a state prisoner's application for a writ of habeas corpus if the state court adjudication pursuant to which the prisoner is held "resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States." 28 U.S.C. § 2254(d)(1) . In this context, "clearly established law" signifies "the holdings, as opposed to the dicta, of this Court's decisions." Williams v. Taylor , 529 U.S. 362, 412, 120 S. Ct. 1495, 146 L. Ed. 2d 389 (2000) .
In this case, it is abundantly clear that our precedents do not clearly establish the categorical rule on which [*12] the Court of Appeals relied, i.e. , 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.
* * *
[In Maryland v. Shatzer , 559 U.S. ___, (2010) the Court refused to determine whether a bright line rule existed that would determining the applicability of Miranda in prison settings. The Court noted that it never had determined when a prisoner would be considered in custody fo r Miranda purposes, but that there must have been a danger of coercive interrogation that Miranda was intended to guard against. The Court felt that the Court of Appeals misread an earlier case to find that any one in custody in a prison was always in custody for Miranda purposes.]
Determining whether an individual's freedom of movement was curtailed, however, is simply the first step in the analysis, not the last. Not all restraints on freedom of movement amount to custody for purposes of Miranda . We have "decline[d] to accord talismanic power" to the freedom-of-movement inquiry, Berkemer , 468 U.S., at 437, 104 S. Ct. 3138, 82 L. Ed. 2d 317 , and have instead asked the additional question whether the relevant environment presents the same inherently coercive pressures as the type of station house questioning at issue in Miranda . "Our cases make clear . . . that the freedom-of-movement test identifies only a necessary and not a sufficient condition for Miranda custody." Shatzer , 559 U.S., at ___, 130 S. Ct. at 1221, 175 L. Ed. 2d at 1054 .
[Determining whether a person has been questioned in an inherently coercive atmosphere is subject to an analysis of the individual situation to determine whether Miranda custody actually existed. The Court noted that when a person is already serving a term of imprisonment, including the ordinary restrictions that prison life involves, going to a conference room for interrogation does not involve an inherently compelling pressure that might exist when a person is removed from familiar surroundings and subjected to questioning at an unfamiliar police station. The Court also noted that prisoner, unlike an individual who has not been sentenced to a term of years, would not likely be pressured to speak by the hope that he might be soon released from custody. And a prisoner, unlike the person who was recently removed from a public street to an interrogation room, prisoner knows that an interrogating law-enforcement officer probably lacks the authority to shorten or end his sentence and, therefore, less coercion would be present, if at all.]
* * *
In short, standard conditions of confinement and associated restrictions on freedom will not necessarily implicate the same interests that the Court sought to protect when it afforded special safeguards to persons subjected to custodial interrogation. Thus, service of a term of imprisonment, without more, is not enough to constitute Miranda custody.
The two other elements included in the Court of Appeals' rule--questioning in private and questioning about events that took place outside the prison--are likewise insufficient.
Taking a prisoner aside for questioning--as opposed to questioning the prisoner in the presence of fellow inmates--does not necessarily convert a "noncustodial situation . . . to one in which Miranda applies." Mathiason , 429 U.S., at 495, 97 S. Ct. 711, 50 L. Ed. 2d 714 . When a person who is not serving a prison term is questioned, isolation may contribute to a coercive atmosphere by preventing family members, friends, and others who may be sympathetic from providing either advice or emotional support. And without any such assistance, the person who is questioned may feel overwhelming pressure to speak and to refrain from asking that the interview be terminated.
By contrast, questioning a prisoner in private does not generally remove the prisoner from a supportive atmosphere.
* * *
Finally, we fail to see why questioning about criminal activity outside the prison should be regarded as having a significantly greater potential for coercion than questioning under otherwise identical circumstances about criminal activity within the prison walls. In both instances, there is the potential for additional criminal liability and punishment. If anything, the distinction would seem to cut the other way, as an inmate who confesses to misconduct that occurred within the prison may also incur administrative penalties, but even this is not enough to tip the scale in the direction of custody. "The threat to a citizen's Fifth Amendment rights that Miranda was designed to neutralize" is neither mitigated nor magnified by the location of the conduct about which questions are asked. Berkemer , 468 U.S., at 435, n. 22, 104 S. Ct. 3138, 82 L. Ed. 2d 317 .
For these reasons, the Court of Appeals' categorical rule is unsound.
* * *
* * *
Taking into account all of the circumstances of the questioning--including especially the undisputed fact that respondent was told that he was free to end the questioning and to return to his cell--we hold that respondent was not in custody within the meaning of Miranda .
* * *
The judgment of the Court of Appeals is Reversed .
Contact Us | Website ©2008 Jefferson Ingram. Last updated
March 2012. Webmaster: L. Ingram.