Howes v. Fields

Police were not required to issue Miranda warnings when interrogating a prisoner for an unrelated offense when the totality of the circumstances suggest that the prisoner was not in an inherently coercive situation

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 Supreme Court reversed and rejected the Sixth Circuit’s “categorical rule” that (1) imprisonment, (2) questioning in private, and (3) questioning about events in the outside world automatically trigger a custodial situation for Miranda purposes. The Court further held that (1) questioning a person who is already in prison does not generally involve the shock that very often accompanies arrest; (2) a prisoner is unlikely to be lured into speaking by a longing for prompt release; and (3) a prisoner knows that his questioners probably lack authority to affect the duration of his sentence. Thus, the Court held that service of a prison term, without more, is not enough to constitute Miranda custody. Rather, in determining whether Miranda warnings are necessary when questioning prisoners, one must conduct a fact specific inquiry, based on the totality of the circumstances, as to whether a suspect subjectively felt as if his liberty or freedom of movement had been impaired. The Court held in this case that because Fields (1) was told from the outset that he was free to leave; (2) not physically restrained in a well-lit room; (3) the door to the conference room was left open; and (4) that Fields was repeatedly offered food and water that it would be unreasonable for Fields to conclude that he was not free to leave or terminate the interrogation at any time.