Ann Arbor Criminal Defense Blog
The United States Supreme Court, in Howes v. Fields, rejected a per se rule that questioning a prison inmate in a room isolated from the general prison population about events occurring outside the prison is custodial interrogation.
The Fifth Amendment of the Constitution requires that a person in “custodial interrogation” be read Miranda rights, those rights which come from the case of Miranda v. Arizona.
Fields was serving a sentence in a Michigan jail. He was taken to a room in another section of the facility by a corrections officer. In this room, two sheriff’s deputies questioned him about allegations of criminal acts occurring outside the prison.
At the outset of the interview and later on, Fields was advised that he was free to leave and return to his cell. The deputies did not read Fields the Miranda rights. Fields became agitated during the interview and began to yell. He testified that one of the deputies, using expletives, told him to sit down, and that if he wanted to leave he could. Fields eventually confessed to the alleged crimes and was subsequently charged.
Fields moved to suppress the confession, based on Miranda. The trial court denied his motion.
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The Michigan Court of Appeals affirmed the trial court, ruling that Fields was not in custody for the purposes of Miranda, and therefore no Miranda warnings were required. The Michigan Supreme Court denied review of the case. Fields petitioned for a writ of habeus corpus in Federal District Court and was granted relief.
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The Sixth Circuit affirmed, holding that a prisoner is in custody within the meaning of Miranda if the prisoner is taken away from the general prison area and questioned about events that occurred outside the prison. The Sixth Circuit held that the interview of Fields in the room was a “custodial interrogation” because isolation from the rest of the prison combined with questioning about allegation outside the prison makes such an interrogation custodial per se.
The Supreme Court rejected this rule and then when on to explain why the per se rule declared by the Sixth Circuit would not necessarily be custodial interrogation in any event.
The term “custody” refers to circumstances where the danger of coercion is present. A court will look to the objective circumstances of the interrogation to find whether a person is in custody. More specifically, the question is whether a reasonable person would have felt free to end the interrogation and leave the situation. Freedom of movement is not necessarily sufficient to define whether a person is in custody, however.
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According to the Court, there are several reasons why a person already living in a jail-environment would not be in custody for Miranda purposes.
A person who is taken into a police-dominated atmosphere, such as a police station, after being arrested on the street is more clearly taken into a custodial environment. A prisoner who is already living in a custodial environment, however, does not undergo this change in environment.
Living in a custodial environment, the Court reasoned, removes some of the shock of being in incarceration and many of the pressures of coercion. Furthermore, a prisoner would not be as vulnerable to promises of prompt release from incarceration.
The Court then addressed the other two parts of the situation here, that of taking a prisoner away from the general population and questioning about events occurring outside the prison.
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Isolating a prisoner from the general population does not take the prisoner away from a support structure of family and friends in the way that removing a person from the street and taking him or her to a police station would. Also, questioning a prisoner in the presence of other prisoners would be inappropriate, as the prisoner being questioned would not be free to speak to officers and could be placed in physical danger from the questioning.
The Court did acknowledge that removing a prisoner from the general population would sometimes place additional limitations on the prisoner’s freedom, but brushed this concern off saying that this was a fact of prison life, such as when a prisoner is escorted to different parts of the prison.
Lastly, the Court found no distinction between questioning on matters occurring outside or inside the prison. Either way, the prisoner was being questioned about behavior that could lead to criminal liability.
The Court ultimately held that Fields was not subject to custodial interrogation.
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