Howes v. Fields

PETITIONER: Carol Howes, Warden
RESPONDENT: Randall Lee Fields
LOCATION: Lenawee County Jail

DOCKET NO.: 10-680
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Sixth Circuit

CITATION: 565 US (2012)
GRANTED: Jan 24, 2011
ARGUED: Oct 04, 2011
DECIDED: Feb 21, 2012

ADVOCATES:
Elizabeth L. Jacobs - for the respondent
Ginger D. Anders - on behalf of the united states, as amicus curiae, supporting the respondent
Ginger D. Anders - Assistant to the Solicitor General, Department of Justice, for the United States, as amicus curiae, supporting the petitioner
John J. Bursch - Solicitor General of Michigan, for the petitioner

Facts of the case

A jury found Randall Fields guilty of two counts of third-degree criminal sexual conduct for the sexual abuse of a thirteen-year-old child. Fields was in jail on a disorderly charge when Lenawee County, Michigan deputies questioned him about allegations of sex with a minor. The sex case was unrelated to the one Fields was in jail for at the time.

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 warnings before questioning. The state court reasoned that because Fields was free to return to the jail and was questioned on a matter unrelated to his incarceration, there was no obligation to provide him warnings under Miranda.

Fields then filed a petition for a writ of habeas corpus under 28 U.S.C. § 2254 claiming that his Fifth Amendment right against self-incrimination was violated, and the U.S. District Court agreed. The United States Court of Appeals for the Sixth Circuit affirmed.

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?

Media for Howes v. Fields

Audio Transcription for Oral Argument - October 04, 2011 in Howes v. Fields

Audio Transcription for Opinion Announcement - February 21, 2012 in Howes v. Fields

John G. Roberts, Jr.:

Justice Alito has our opinion this morning in case 10-680, Howes verus Fields.

Samuel A. Alito, Jr.:

This case which comes to us from the Sixth Circuit concerns the test for determining whether a prisoner is in custody within the meaning of the Miranda rule.

Respondent Fields was serving a sentence in the Michigan jail when he was taken from his cell to a conference room and questioned about the sexual abuse of a 12-year-old boy.

He was not given Miranda warnings or advised that he did not have to speak with the interviewing deputies, but he was told more than once that he was free to leave and return to his cell.

Fields confessed and he was later charged with criminal sexual conduct and convicted.

The state courts rejected Fields' contention that his confession should have been suppressed because he was subjected to custodial interrogation without a Miranda warning, but the Federal District Court granted habeas relief and the Sixth Circuit affirmed holding that our precedents clearly establish that a prisoner is always in custody within the meaning of Miranda when he is removed from general prison population and questioned about conduct that occurred outside the prison.

Our decisions, however, do not clearly establish such a categorical rule and therefore the Court of Appeals erred in holding that this rule provides a permissible basis for federal habeas relief under the relevant provision of the Antiterrorism and Effective Death Penalty Act of 1986.

Indeed, the rule applied by the Sixth Circuit does not represent a correct interpretation of our Miranda case law.

Under Miranda, custody is a term of art, not all restraints on freedom of movement amount to Miranda custody and imprisonment alone is not enough to create a custodial situation for Miranda purposes.

Although taking a prisoner aside for questioning may necessitate some additional limitations on the prisoner's freedom of movement, it does not necessarily convert a noncustodial situation into Miranda custody and neither does questioning a prisoner about criminal activity that took place outside the prison have a greater potential for coercion than questioning under otherwise identical circumstances about criminal activity that took place within prison walls.

The record in this case reveals that respondent was not taken into custody for Miranda purposes.

For these reasons and others stated in our opinion, the judgment of the Court of Appeals is reversed.

Justice Ginsburg has filed an opinion concurring in part and dissenting in part in which Justice Breyer and Justice Sotomayor have joined.