Howes v. Fields, 565 U.S. 499 (Feb. 21, 2012)

The Sixth Circuit erroneously concluded that a prisoner is in custody within the meaning of Miranda if the prisoner is taken aside and questioned about events that occurred outside the prison. While incarcerated, Randall Fields was escorted by a corrections officer to a conference room where two sheriff’s deputies questioned him about allegations that, before he came to prison, he had engaged in sexual conduct with a 12-year-old boy. In order to get to the conference room, Fields had to go down one floor and pass through a locked door that separated two sections of the facility. Fields arrived at the conference room between 7 and 9 pm and was questioned for between five and seven hours. At the beginning of the interview, Fields was told that he was free to leave and return to his cell. Later, he was again told that he could leave whenever he wanted. The interviewing deputies were armed, but Fields remained free of handcuffs and other restraints. The door to the conference room was sometimes open and sometimes shut. About halfway through the interview, after Fields had been confronted with the allegations of abuse, he became agitated and began to yell. One of the deputies, using an expletive, told Fields to sit down and said that “if [he] didn’t want to cooperate, [he] could leave.” Fields eventually confessed to engaging in sex acts with the boy. Fields claimed that he said several times during the interview that he no longer wanted to talk to the deputies, but he did not ask to go back to his cell before the interview ended. When he was eventually ready to leave, he had to wait an additional 20 minutes or so because an officer had to be called to escort him back to his cell, and he did not return to his cell until well after when he generally went to bed. At no time was Fields given Miranda warnings or advised that he did not have to speak with the deputies. Fields was charged with criminal sexual conduct. Fields unsuccessfully moved to suppress his confession and the jury convicted him of criminal sexual conduct. After an unsuccessful direct appeal, Fields filed for federal habeas relief. The federal district court granted relief and the Sixth Circuit affirmed, holding that the interview was a custodial interrogation because isolation from the general prison population combined with questioning about conduct occurring outside the prison makes any such interrogation custodial per se. Reversing, the Court stated: “it is abundantly clear that our precedents do not clearly establish the categorical rule on which 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,” the Court stated, “we have repeatedly declined to adopt any categorical rule with respect to whether the questioning of a prison inmate is custodial.” The Court went on to hold that based on the facts presented, Fields was not in custody for purpose of Miranda.