Supreme Court to Decide Whether Miranda Rights Apply to Prisoners in Howes v. Fields

The Supreme Court has started its latest term, and one of the first items on its agenda is whether prisoners have Miranda rights.

As this blog noted earlier, Miranda v. Arizona turned 45 this year. It enshrined the Fifth Amendment right to receive a warning before being interrogated by the police: “You have the right to remain silent. Anything you say can and will be held against you in a court of law. You have the right to speak to an attorney, and to have an attorney present during any questioning. If you cannot afford an attorney, one will be appointed for you.” The idea is to prevent an individual from saying something incriminating that could put him or her behind bars.

But what if you are already in prison for a state or federal crime? Does a Miranda warning still have any relevance, or do the convicted leave their Fifth Amendment right at the jailhouse door? That is what the Supreme Court will consider after October 4th arguments on Howes v. Fields.

In 2002, Randall Lee Fields was convicted in Michigan of two counts of third-degree sexual conduct. He was sentenced to 10 to 15 years in prison. Before trial, Fields sought to suppress an incriminating statement that he made to police while in a county jail on an unrelated charge. A police officer had taken Fields into a conference room in the sheriff’s department to answer questions. Fields was wearing a prison uniform, but was not handcuffed or restrained in any way. Without first reading him his Miranda rights, two sheriff’s deputies proceeded to question Fields for seven hours about his relationship with a minor. Fields was told that he could leave at any time, but he felt that he had to stay and answer. Fields never asked for an attorney or to be returned to his cell.

His motion was denied and the incriminating statement was brought in as evidence. Fields made a federal appeal, and his case was eventually heard by the Sixth Circuit Court of Appeals. The Sixth Circuit found that the state court decision was contrary to Mathis v. United States (1961), which created the rule that “a Miranda warning is required whenever an incarcerated individual is isolated from the general prison population and interrogated . . . about conduct occurring outside of the prison.” Just last year, the Supreme Court found in Maryland v. Shatzer that an inmate removed from his cell and interrogated about an unrelated crime should have a Miranda warning.

Now the Supreme Court will determine whether Howes v. Fields meets the Mathis standard. A lot rests on whether Fields was in a comfortable environment, or one controlled by the interrogating officers. Someone’s private office is less likely to be considered “custody” than a police interrogation room. While there is reason to believe that the Supreme Court will find that Fields is like Mathis, the Court hasn’t always been friendly to Miranda rights. Just last year in Berghuis v. Thompkins, the Court held that suspects who wanted to exercise their “right to remain silent” had to say so specifically. So all those suspects who thought they simply had to remain silent might find themselves incriminated.

Prisoners can be abused by police interrogation techniques as much as non-prisoners, and there is no reason to find an exception in Howes v. Fields. That is why a criminal defense attorney should be present when they are questioned. Otherwise, you might have a situation where police start bringing prisoners to “comfortable” surroundings to dodge the Miranda rule, claiming that their questioning doesn’t amount to interrogation in police custody.

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