Supreme Court Decides Howes v. Fields
On February 21, 2012, the Supreme Court decided Howes v. Fields, No. 10-860, holding that a prison inmate who is questioned by law enforcement officers in private about his conduct outside prison is not necessarily "in custody" for purposes of the warning requirement of Miranda v. Arizona, but that such a determination depends on the other surrounding circumstances as well.
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 alleged pre-incarceration criminal activity. Fields was not given Miranda warnings or advised that he did not have to speak with the deputies. Some of the surrounding circumstances suggested that Fields knew he did not have to talk with the deputies, while other circumstances suggested that he was not free to return to his cell. Fields eventually confessed to other crimes. At trial, the court denied Fields' motion to suppress his confession under Miranda v. Arizona, 384 U. S. 436 (1966), and he was convicted. The Michigan Court of Appeals affirmed, but a federal district court and the Sixth Circuit held that Fields was entitled to habeas corpus relief because the interview was a custodial interrogation within the meaning of Miranda.
The Supreme Court reversed, rejecting the Sixth Circuit's reading of Mathis v. United States, 391 U.S. 1 (1968) to hold that isolation from the general prison population combined with questioning about conduct occurring outside prison constitutes custodial interrogation per se. The Court held that its precedents did not support such a categorical rule, stressing that the determination of whether interrogation is custodial rests on how a suspect would gauge his or her freedom of movement in light of "all of the circumstances surrounding the interrogation." Because the facts in this case were consistent with an environment in which a reasonable person would have felt free to end the questioning and leave, subject to the ordinary restraints of life behind bars, the Court held that the interrogation was not custodial.
Justice Alito delivered the opinion of the Court, in which Chief Justice Roberts and Justices Scalia, Kennedy, Thomas and Kagan joined. Justice Ginsburg filed a dissenting opinion, in which Justices Breyer and Sotomayor joined.
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