Howes v. Fields

Randall Fields was serving a sentence in Lenawee County Jail in Michigan when he was escorted to a conference room and questioned by two sheriff's deputies.

[4] Fields made statements during the interrogation that would to his being prosecuted and convicted for third-degree criminal sexual conduct.

[5] The Court relied on a recent Sixth Circuit decision, Simpson v. Jackson,[8] which was factually similar, and was controlling precedent for this case:In both our case and Simpson, "as in Mathis, state agents unaffiliated with the prison isolated an inmate and questioned him about an unrelated incident without first giving Miranda warnings."

Moreover, the state court judges in both cases, without even citing Mathis, ruled that statements obtained from such questioning was admissible.

And in both cases, the failure to heed Mathis and forego the issuance of Miranda warnings was "improper" and "any resulting statements [should have been] suppressed" by the trial court.The Court also noted a recent Supreme Court case, Maryland v. Shatzer, which said in part:Interrogated suspects who have previously been convicted of crime live in prison.

When they are released back into the general prison population, they return to their accustomed surroundings and daily routine—they regain the degree of control they had over their lives prior to the interrogation.Correspondingly, the Court of Appeals stated, "[a] prisoner is in custody when he is removed from his 'normal life' by being taken from his cell to an isolated area, such as a closet or conference room, for the purpose of interrogation.

[9] Writing for the majority, Justice Alito addressed two issues: 1) that the AEDPA required that habeas corpus petitions address issues of "clearly established federal law", and the Sixth Circuit's interpretation of Miranda and Mathis did not qualify, and 2) that even if this were a direct appeal instead of a habeas corpus petition, Fields' interrogation could not be considered "custodial.

On the contrary, we have repeatedly declined to adopt any categorical rule with respect to whether the questioning of a prison inmate is custodial.Rather, the Court had consistently relied on case-by-case examination of the circumstances of an interrogation to determine whether it was custodial.

The cases that the Sixth Circuit had cited, such as Mathis and Shatzer, had involved their own factual inquiries, and could not be relied on for establishing any categorical rule.

After detailing why the Sixth Circuit's categorical rule was "unsound," the majority said that Fields was not, in fact, in custody for Miranda purposes, primarily because Fields was told he could leave when he wanted:To be sure, respondent did not invite the interview or consent to it in advance, and he was not advised that he was free to decline to speak with the deputies.