Howes v. Fields

Whether police are required to issue Miranda warnings to an incarcerated prisoner during a criminal investigation of an unrelated offense.

Fields was arrested for disorderly conduct. While he was serving his jail sentence, police separated Fields from the general jail population, and questioned him for seven hours about possible sex crimes with a minor. Fields was never given Miranda warnings, but was told he did not have to cooperate if he so chose. Throughout the seven hour interrogation, Fields told the officers he did not want to participate any longer, yet despite those objections, the questions continued and Fields made several incriminating statements. The trial court denied Fields’ motion to suppress the incriminating statements and he was subsequently convicted and sentenced to fifteen years imprisonment. After exhausting his state remedies, Fields filed a pro se federal habeas claim on the same grounds. The Federal District Court conditionally approved Fields’ habeas claim and the Sixth Circuit affirmed.

The State of Michigan appeals and argues that the Sixth Circuit erred in creating a categorical rule that a prisoner is always “in custody,” even when being questioned for conduct that occurred outside of the jail. The State argues that although Fields was locked in the interrogation room and was escorted to and from the interrogation by other officers, that that did not amount to the “police-dominated” atmosphere Miranda intended to remedy. In response, Fields argues that the Sixth Circuit was correct and that he was clearly “in custody” when interrogated and thus the trial court erred in denying his motion to suppress.