Carol Howes (Warden) v.
Randall Lee Fields
Argued October 4, 2011
Decided February 21,2012
Paul M. Leclair
Facts
Fields, in prison for domestic violence, was removed from his cell and escorted by
a guard to a conference room for questioning about suspected sexual abuse of a
13-year-old boy prior to his imprisonment.
He was initially told that he was free to leave and return to his cell, and he was
reminded of this at least once during the five to seven hours of interrogation.
Two armed sheriff’s deputies conducted the questioning, but Fields was
unrestrained and the door was sometimes left ajar.
He was offered food and drink.
Fields eventually confessed, and was taken back to his cell sometime after
midnight, after a 20-minute wait for an escort.
No Miranda warnings were ever given nor was he advised that he did not have to
speak with the deputies.
Question
Does federal law automatically require Miranda warnings before questioning jail or prison inmates about issues unrelated to the cases for which they were incarcerated?
Legal Issue
Fields was found guilty of two counts of third-degree criminal sexual conduct for the
sexual abuse of a thirteen-year-old child.
Fields filed an appeal of right in the Michigan Court of Appeals claiming that his
statements were inadmissible because he had not been given his Miranda warning before questioning, moved to suppress his confession, alleging a Miranda violation.
Michigan Court of Appeals affirmed, ruling that Fields had not been in Miranda
“custody” so no warnings were required.
The Michigan Supreme Court denied review, but on federal habeas the district court
granted relief and the Sixth Circuit affirmed.
The Sixth Circuit held that United States Supreme Court precedents “clearly
established” (this is the statutory federal habeas standard) a rule that Miranda warnings must be given when guards remove a prisoner from the general population and interrogate him about criminal conduct that took place 0utside the prison. Ruling (6-3, Alito)
It is “abundantly clear” that no such rule is
“clearly established.” In fact, the Sixth Circuit’s rule is “simply wrong.” That court “misread” our precedents and its reasoning “strains credulity.” “Imprisonment alone is not enough to create a custodial situation within the meaning of Miranda.” On this record, Fields was clearly not in “custody” and Miranda warnings were not required.
Ruling
First, Ilinois v. Perkins (1990) and Maryland v. Shatzer
(2010) expressly left the question open. Similarly,
Mathis (1968) did not decide the question, and neither did Miranda itself. As has always been the case,
Miranda “custody” is a “term of art” that must focus on the totality of the circumstances. The test is
“whether, in light of the objective circumstances ..., a reasonable person would have felt he or she was not at liberty to terminate the interrogation and leave.” Thus, for example, in Berkemer (1984), we held there was no Miranda custody even though a person stopped by the roadside for a traffic violation is not “free to leave.”
Ruling
Questioning conducted during imprisonment
does not necessarily equal Miranda custody, for at least three
