Howes v. Fields
Randall Lee Fields was an inmate in a Michigan prison when investigators arrived to question him about another crime. Fields was taken to a conference room where sheriff’s deputies told him that he was free to leave and return to his cell whenever he wanted. He was not handcuffed or shackled. He was offered food and water during the several hours of unMirandized interrogation, during which he confessed.
State courts ruled that Miranda did not apply to the interrogation; however, both the federal district court and the Sixth Circuit ordered Fields released or retried, based on Miranda error. Relying on those passages from Shatzer quoted above, the Sixth Circuit said that Fields was in custody and should have been Mirandized. On further appeal, the U.S. Supreme Court reversed.
The court declared that “Mathis did not hold that imprisonment, in and of itself, is enough to constitute Miranda custody.” As to the passages in Shatzer relied on by the Sixth Circuit, the Supreme Court said these statements meant only that “the issue of custody was not contested.” The court majority then basically adopted the reasoning of the Mathis dissent, focusing on the familiarity of prison surroundings for an inmate and deciding that prisoners are not necessarily in custody. The court said this:
“Imprisonment alone is not enough to create a custodial situation within the meaning of Miranda. Taking a prisoner aside for questioning does not necessarily convert a noncustodial situation to one in which Miranda applies. Taking into account all of the circumstances of the questioning — especially the fact that respondent was told that he was free to end the questioning and return to his cell — we hold that respondent was not in custody within the meaning of Miranda.”
This decision means that officers who want to interrogate an inmate may remove the inmate to an interview room, avoid the use of added restraint
s, advise him that he is free to end the interview and return to his cell at any time, and take an admissible statement without Miranda warnings. The Supreme Court was able to arrive at this concrete guideline for inmate interrogation in only 46 years.
Devallis Rutledge is a former police officer and veteran prosecutor who currently serves as special counsel to the Los Angeles County district attorney. He is the author of several books, including “Investigative Constitutional Law.”
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