Craig Wilson v. Burl Cain, Warden
2011 U.S. App. LEXIS 9622
| 5th Cir. | 2011Background
- Wilson, a Louisiana prisoner, was convicted of attempted manslaughter for an attack on another inmate and sentenced to 40 years.
- After state habeas relief denials, Wilson challenged the Miranda claim in a §2254 petition under AEDPA.
- During the 1997 incident, Wilson spoke to WCI officers in a post-fight interview; he was handcuffed and not free to leave.
- The state court admitted Wilson’s statements after denying suppression, treating the questioning as noncustodial, investigative conduct.
- On direct appeal, the Louisiana court affirmed, with one judge dissenting on Miranda custody; state supreme court denied certiorari.
- The district court denied relief under AEDPA; this court granted a COA on the Miranda custody issue and affirmed denial of relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the state court correctly applied Miranda custody law. | Wilson argues he was in custody and entitled to warnings. | Wilson contends the questioning resembled custodial interrogation requiring warnings. | No; state court's custody ruling was not an unreasonable application of clearly established law. |
| Whether prison context can trigger Miranda under Mathis/Shatzer framework. | Inmates may be interrogated as custodial if coercive conditions exist. | Prison staff conducting routine post-fight questioning does not automatically trigger Miranda. | Not objectively unreasonable to conclude non-custodial, on-the-scene questioning. |
| Whether AEDPA deference applies to circuit-derived distinctions in custody determinations. | Circuit cases support Miranda rights in this prison context. | State court findings align with existing circuit practice; deference warranted. | AEDPA deferential review applied; no unreasonable application found. |
Key Cases Cited
- Cervantes v. Walker, 589 F.2d 424 (9th Cir. 1978) (on-scene questioning factors; prison setting and custody analysis)
- Conley v. United States, 779 F.2d 970 (4th Cir. 1985) (inmate questioned by prison guard not in custody)
- Scalf v. United States, 725 F.2d 1272 (10th Cir. 1984) (prison guard questioning not custodial interrogation)
- Fields v. Howes, 617 F.3d 813 (6th Cir. 2010) (Miranda warnings required when outside-prison agents question inmate about conduct outside jail)
- Shatzer v. Maryland, 130 S. Ct. 1213 (2010) (break in custody may terminate Miranda protections; outer bounds clarified)
- Harrington v. Richter, 131 S. Ct. 770 (2011) (AEDPA deference standard and fairminded jurists concept)
- Premo v. Moore, 131 S. Ct. 733 (2011) (heightened deference under AEDPA; extreme malfunctions required for relief)
- Renico v. Lett, 130 S. Ct. 1855 (2010) (AEDPA review; deference to state court decisions)
- Thaler v. Haynes, 130 S. Ct. 1171 (2010) (AEDPA framework and deference principles)
- Wright v. Van Patten, 128 S. Ct. 743 (2008) (clearly established law and reasonable-application standard under AEDPA)