Miranda Warnings In Prison Settings

The U.S. Supreme Court issued an opinion in the case of Howes v. Fields today. The case involved a collateral habeus corpus petition on a criminal sexual conduct conviction that had been affirmed on direct appeal. The defendant was incarcerated in Michigan when he was taken from his cell to a conference room where he was questioned by armed deputies for between 5-7 hours about allegations that he sexually abused a 12 year old before he was incarcerated. He was told he could go back to his cell at any time and the door was sometimes open and sometimes closed. He did not ask to leave and eventually confessed to the allegations and that confession was used to obtain a conviction. Both at trial and on direct appeal he attempted to have the confession suppressed as he was never given Miranda warnings during the questioning that he characterized as custodial. This argument was rejected.

However, the habeus petition was granted by the federal district court and 6th Circuit Court of Appeals on the basis that the defendant was not given a Miranda warning as required during a custodial interrogation. The 6th circuit reasoned that an interrogation in a jail or prison setting is custodial if 1) It occurred during imprisonment, 2) Involved questioning in private about 3) events that occurred in the outside world.

The Supreme Court, in an opinion authored by Justice Alito, rejected this reasoning and held that custodial interrogation must be judged by whether the circumstances present a serious danger of coercion. Namely, would a reasonable person have felt free to terminate the interrogation and leave provided that the interrogation environment presents the same coercive pressures as the station house interrogation that was at issue in Miranda v. Arizona. The Court found that there can be a break in custody during an uninterrupted term of incarceration. Factors such as the length of the interrogation, that the interrogators were armed and used sharp language, and the fact that the defendant was not told he could decline the interview favor a finding that the interrogation was custodial. However other factors offset these as the defendant was told he could leave and go back to his cell at any time, he was not physically restrained, the conference room was well lit and not uncomfortable, the door was sometimes open, and he was offered food and water.

Justice Ginsburg dissented joined by Justices Sotomayor and Breyer stating, "I would not train, as the Court does, on the question whether there can be custody within custody. Instead, I would ask, as Miranda put it, whether Fields was subjected to 'incommunicado interro- gation . . . in a police-dominated atmosphere,' 384 U. S., at 445, whether he was placed, against his will, in an inher- ently stressful situation, see id., at 468, and whether his 'freedom of action [was] curtailed in any significant way,' id., at 467. Those should be the key questions, and to each I would answer 'Yes.'". Ginsburg focused on the fact that the defendant was not told he could decline the interview with the deputies, that he felt trapped, that he believed the deputies would not allow him to leave the room despite their statement that he could, that he told the deputies he did not wish to speak with them anymore multiple times, that although he was given water he was not given his night medications, and that the deputies were armed.

s/ Kurt Koehler
308 1/2 S. State Street Suite 36
Ann Arbor, Michigan 48198
(Washtenaw County)