Imprisoned But Not In Custody For Miranda Purposes

In a slip opinion delivered by Justice Alito on February 21, 2012, the United States Supreme Court reversed the Sixth Circuit and held that a Michigan state prisoner (“Fields”), who was removed from his cell and questioned by sheriff’s deputies about criminal activity that he allegedly engaged in before imprisonment, was not taken into custody for Miranda purposes (Carol Howes, Warden v. Randall Fields, 565 U.S. ___ (2012)). Consequently, the Supreme Court decided that Fields’ confession was improperly suppressed by the Sixth Circuit and his conviction was upheld.

Of relevance, Fields was brought from his cell to a conference room and questioned for five to seven hours by armed deputies. At no time was Fields given Miranda warnings or told that he had the right to remain silent. However, Fields was told he was free to leave and return to his cell. Several times during the interview, Fields stated that he no longer wanted to talk with the deputies, but he did not ask to return to his cell. After Fields confessed, the interview was concluded and Fields was returned to his cell long after he normally retired.

The trial court denied Fields’ motion to suppress the confession and the Michigan Court of Appeals affirmed. After the Michigan Supreme Court denied discretionary review, Fields filed a petition for writ of habeas corpus in the federal district court and the court granted relief. The Sixth Circuit affirmed the habeas relief, ruling that the prison interview was a per se custodial interrogation within the meaning of Miranda.

The U.S. Supreme Court, however, disagreed with the Sixth Circuit’s decision and held that imprisonment alone does not categorically constitute Miranda custody. As support for its conclusion, the Supreme Court reasoned that questioning an individual who is already imprisoned does not “generally involve the shock that very often accompanies arrest.” Also, a prisoner is unlikely to be lured into speaking in hopes of release and knows that the questioners probably lack authority to affect his sentence.

In Fields’ case, when looking at the circumstances surrounding his interrogation, the Supreme Court determined that Fields was not taken into custody for Miranda purposes. Fields was told he was free to leave, was not physically restrained during the interview, and was offered food and water. Also, the conference room door was sometimes left open during the interview. According to the Supreme Court, a reasonable person would have felt free to terminate the interview and leave.

Justice Ginsburg, joined by Justices Breyer and Sotomayor, concurred in part and dissented in part. Justice Ginsburg agreed that the law on what constitutes Miranda custody is not “clearly established” so as to entitle Fields to habeas relief. However, if the case was before the Supreme Court on direct review, Justice Ginsburg would have voted to suppress the confession in violation of Miranda.

The Supreme Court’s decision confirms that there is no absolute rule for determining Miranda custody in prison settings. The reasoning applied in the Field’s case also suggests that in future cases the Supreme Court may require a significantly coercive environment to constitute Miranda custody for non-incarcerated individuals as well.