Supreme Court declines to expand definition of custodial for Miranda purposes

[JURIST] The US Supreme Court [official website] ruled 6-3 [opinion, PDF] Tuesday in Howes v. Fields [SCOTUSblog backgrounder] that a US Court of Appeals for the Sixth Circuit categorical rule that all private questioning of prisoners about outside events is per se custodial, requiring Miranda warnings to be given, is not clearly established by Supreme Court precedent. The court also declined to establish a rule that interrogations are per se custodial for the purposes of Miranda, when a prisoner is questioned in private about events occurring outside the prison. Respondent Randall Fields was questioned by investigators about a child sex-abuse case while he was in the county jail serving a 45-day sentence for disorderly conduct. A lower court found that Fields did not have to be given his Miranda rights because the investigators were questioning him about a separate crime. This decision was reversed [opinion] by the Sixth Circuit, holding that Miranda is necessary anytime the suspect is isolated from the rest of the jail inmates in a situation where the suspect would be likely to incriminate himself. In an opinion delivered by Justice Samuel Alito, the Supreme Court reversed:

In short, standard conditions of confinement and associated restrictions on freedom will not necessarily implicate the same interests that the Court sought to protect when it afforded special safeguards to persons subjected to custodial interrogation. Thus, service of a term of imprisonment, without more, is not enough to constitute Miranda custody.
The court further stated that the determination of custody should focus on all features of the interrogation including the manner and language summoning the prisoner to the questioning and the manner in which the interrogation occurs. Justice Ruth Bader Ginsburg filed an opinion concurring with the majority as to whether Supreme Court precedent clearly establishes a categorical rule for what constitutes custody but dissented on the issue of whether Fields was in custody for Miranda purposes. Ginsburg was joined in her opinion by Justices Stephen Breyer and Sonia Sotomayor.

During oral arguments, attorneys representing the state of Michigan argued [JURIST report] that since Fields invoked his right to return to his cell, despite being confined in jail, a reasonable person in jail being taken to an interrogation room would have understood it was an interrogation and Miranda was unnecessary. They further argued against the per se rule that was created by the Sixth Circuit rather than applying the traditional "all the circumstances" test for Miranda. Fields' attorney contended that he felt no freedom to leave and that in a prison or jail situation, a reasonable person would not feel a freedom to leave without being read Miranda rights in that situation.

 

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