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Howes v. Fields | 565 U.S. 499 (2012)
In Miranda versus Arizona, the United States Supreme Court held that suspects in police custody are entitled to certain procedural protections to safeguard their constitutional privilege against self-incrimination. The Court reasoned that being interrogated in a police station is inherently coercive, and that, without safeguards, any statements obtained in such conditions might not be fully voluntary. Thus were born the Miranda warnings. But not everyone in police custody is entitled to them, as the Court explained in Howes versus Fields.
Randall Fields was serving a jail sentence when a guard took him to a conference room in an unfamiliar part of the prison. There, two sheriff’s deputies questioned him about allegations that he’d participated in sexual activities with a minor before he was imprisoned. The interview lasted between five and seven hours, until around two a.m. Fields was never given Miranda warnings or told he didn’t have to talk to the deputies, although he was told he was free to leave any time and return to his cell. The deputies were armed, but Fields wasn’t handcuffed or otherwise restrained. The conference room was reasonably comfortable and the door was sometimes left open. Although Fields said several times that he didn’t want to talk anymore, he never asked to leave. Eventually, Fields confessed.
Fields was convicted. After losing his state appeals, Fields filed a federal habeas petition against Carol Howes, the prison warden, arguing that his constitutional rights had been violated because he never received Miranda warnings. The district court ruled for Fields. The Sixth Circuit affirmed, holding that prisoners are entitled to Miranda warnings whenever they’re isolated from the general prison population for questioning about events occurring outside of prison. The United States Supreme Court granted cert.
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