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Howes v. Fields

Supreme Court of the United States · 2012 · Criminal Procedure

Criminal ProcedureMirandaCustodial InterrogationHabeas CorpusAEDPAMirandacustodyprison interrogation

Facts

While serving a sentence in a Michigan jail, Fields was escorted from his cell to a conference room and questioned by two sheriff's deputies about alleged sexual conduct that occurred before his imprisonment. The interview lasted between five and seven hours; the deputies were armed, but Fields was not handcuffed or otherwise restrained, and the door was sometimes open and sometimes shut. Fields was told at the start and later again that he was free to leave and return to his cell whenever he wanted, though he was never given Miranda warnings. After the interview ended, he waited about 20 minutes for an escort back to his cell and returned well after his normal bedtime.

Issue

Whether Supreme Court precedent clearly established that a prisoner is in Miranda custody whenever he is removed from the general prison population and questioned in private about conduct occurring outside prison, such that federal habeas relief was warranted under AEDPA. Also, whether Fields himself was in custody for Miranda purposes during this interview.

Rule

For Miranda purposes, imprisonment alone does not constitute custody, and neither private questioning nor questioning about outside conduct creates a per se custodial setting. Courts must examine all of the circumstances surrounding a prison interrogation, including how a reasonable person would view his freedom to terminate the interview and whether the setting presents the inherently coercive pressures Miranda was designed to guard against.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

While serving a sentence in a county jail in Columbus, Ohio, Devin Marsh was escorted to an interview room and questioned by two detectives about a burglary committed before he was incarcerated. The detectives told him at the start and again an hour later that he could end the interview and return to his housing unit, and he was not handcuffed, though he needed an escort to move through the jail.

If Devin moves to suppress his statements on the ground that he was automatically in Miranda custody because he was isolated from the general jail population and questioned about an outside crime, how should the court rule?

Explanation. The majority rejected a categorical rule that imprisonment plus private questioning plus questions about outside conduct automatically equals Miranda custody. The proper inquiry is all of the circumstances, including whether a reasonable person would have felt at liberty to terminate the interview and whether the setting involved the inherently coercive pressures Miranda addresses. The need for an escort, standing alone, reflects ordinary prison administration and does not itself establish Miranda custody.