Howes v. Fields
132 S. Ct. 1181
| SCOTUS | 2012Background
- Randall Fields, a prisoner in a Michigan jail, was questioned in a conference room about pre-prison conduct with a 12-year-old boy.
- Interview occurred after Fields was escorted through a guarded prison area, lasting five to seven hours, without Miranda warnings.
- Fields was told he was free to leave, but remained in a controlled interrogation with armed deputies, and the door to the room was sometimes closed.
- He eventually confessed; he waited about 20 minutes to be escorted back to his cell and returned to his cell well past his usual bedtime.
- Michigan courts held Fields was not in Miranda custody; the Sixth Circuit held the interview was custodial, per se, under a rule tying isolation and outside conduct to custody.
- The Supreme Court granted certiorari to review whether the per se custodial rule was clearly established under AEDPA and whether Fields was in custody under Miranda.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether imprisonment plus isolation and outside-conduct questioning creates custodial interrogation | Fields argues isolation from the general population and questioning about outside conduct create custody | The Government argues no per se custody rule; custody depends on all circumstances | Not per se; custody requires a case-specific analysis under Miranda |
| Whether the Sixth Circuit’s custodial rule is clearly established under AEDPA | Fields contends the rule is clearly established | The Government contends the rule is not clearly established | Rule not clearly established; reversed to deny habeas relief on custody ground |
| Whether private questioning and outside-prison conduct alone render custody | Fields contends such factors can create custody | Isolated questioning and outside-conduct are not automatically custodial | Insufficient alone to establish custody; requires broader analysis |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (creation of Miranda warnings to ward off coercive interrogation pressures)
- Berkemer v. McCarty, 468 U.S. 420 (1984) (traffic-stop detention generally not Miranda custody; freedom-of-movement not sole determinant)
- Maryland v. Shatzer, 559 U.S. 98 (2010) (no bright-line rule for incarceration; break in custody can occur in prison; custody depends on coercive pressures)
- Mathis v. United States, 391 U.S. 1 (1968) (imprisonment alone not sufficient to foreclose Miranda custody; per se rule rejected)
- Illinois v. Perkins, 496 U.S. 292 (1990) (undercover questioning by an officer posing as inmate; custody not automatic)
- Mathiason, 429 U.S. 492 (1977) (non-incarcerated interrogation can be custodial depending on circumstances)
- Yarborough v. Alvarado, 541 U.S. 652 (2004) (determinants of custody include surrounding circumstances and coercive atmosphere)