February 21, 2012
U.S. Supreme Court - 2-21-12 - Howes v. Fields
Howes v. Fields Miranda - Prison Inmate – Definition of Custody
Facts: While serving a prison sentence, two deputies interrogated Mr. Fields about an allegation unrelated to his current incarceration. Mr. Fields neither invited nor received any prior notice of the interrogation. To get to the interview room, Mr. Fields walked through the secure prison, through doors, and down a floor. Although not handcuffed or chained, at no point did or could Mr. Fields walk ‘freely’ about the prison. At the beginning of the interrogation, the deputies used the magical language that all cops disingenuously use “you are not under arrest and you are free to go.” However, Mr. Fields could not leave un-escorted. When the interrogation finally ended, five to seven hours later, Mr. Fields waited 20 minutes prior to being let out of the interview room. During the interrogation, the doors closed and opened. Further, Mr. Fields got upset at the allegations, and the deputies cursed and ordered Mr. Fields to sit down at one point. Of course, the deputies extracted a supposed confession. Unfortunately, the 6th Circuit held that the U.S. Supreme Court categorically held that all prison interrogations constitute custody under Miranda, which prompted the U.S. Supreme Court to grant certiorari. Even the dissent conceded, no such prior rule existed for prison interrogations. Once dispensing with the reason they granted cert, the Court then addressed whether the deputies and the prison held Mr. Fields in 'custody' during the interrogation.
Issue: Whether the prison and the deputies held Mr. Fields in custody during the interrogation?
Reasoning: Lay folks hate lawyers and what we do precisely because of reasoning such as this incongruous holding. You can hear someone now, "How can someone in prison not be in 'custody'!? (Along with some choice expletives like, WTF!??). Undeterred by common sense, actual circumstance or real rationale, Justice Alito powered through, and minimized the actual custody which held Mr. Fields during the interrogation. Justice Alito focused on the disingenuous language “you are not under arrest and you are free to go at anytime”, the lack of restraints, and ignored the entire PRISON which held Mr. Fields during the entire interrogation. Hardly in prison voluntarily; not in his home; and not simply driving over to the cop shop for a talk. Instead, a prison held Mr. Fields. Justice Ginsberg, joined by Justices Breyer and Sotomayor, conceded the categorical rule of prison interrogations did not exist, but found under the facts of this case, law enforcement held Mr. Lewis in custody during the interrogation.