Howesv. Fields 2012
Inthe year 2012, the Supreme Court made a decision on Howes V Fieldscase No. 10-860, griping that a prisoner who gets questioned by theofficers of law enforcement privately about his behavior outside theprison is not normally “held custody” for the reasons of thewarning obligation of Miranda vs. Arizona. However, determinationlike that one relies on the other surrounding situations as well.
Fields,a state prisoner from Michigan, got accompanied from his prison cellby a number of law enforcers to a conference room. Here, he gotquestioned by two deputies of sheriffs about the suspected preconfinement criminal activity. He was not awarded the Miranda cautionor told that he was not supposed to converse with the deputies. Someof the surrounding situations showed that Fields was aware he was notsupposed to speak with the deputies, whereas other situations showthat he was not free to go back to his cell. He finally owned up toother crimes. During the trial, the court rejected the motion ofFields to hold back his declaration of guilt under Miranda vs.Arizona, and he was found guilty. The court of appeal of Michiganavowed, however, the sixth circuit and federal district court heldthat Field had the right to habeas mass relief since the interviewwas a custodial questioning within the Miranda meaning (Harr &Hess, 2002).
TheSupreme Court inverted, discarding the reading of the Sixth Circuitof Mathis vs. United States, to hold that separation from thepopulation of the general prison joined with the questioning aboutbehavior happening outside prison comprises custodial questioning perse. The court maintained that its standards did not give support tosuch kind of categorical policy. It insisted that the efforts ofwhether questioning is custodial rests on the manner in which asuspect would measure his or her freedom of movement taking intoconsideration of “every of the situation surrounding questioning.”Since the facts in this case were steady with a surrounding, wherebya reasonable individual would have felt free to finish theinterrogation and go, subject to the normal control of life in thecell, the court maintained that the questioning was not custodial(Harr & Hess, 2002). Justice Alito delivered the opinion of thecourt, whereby Chief Justice Robert and Justices Kagan, Kennedy,Scalia and Thomas joined. A dissenting opinion got filed by JusticeGinsburg, whereby Justices Sotomayor and Breyer joined.
Theprecedents of the court do not vividly establish the categoricalpolicy that the Sixth Circuit used. The court has declinedrepeatedly to agree to any such policy. The Sixth Circuitmisunderstood Mathis, which basically held, as important here, that aconvict who otherwise meets the Miranda custody requirements is nottaken outside Miranda range since he got imprisoned for an offensethat was unconnected. It did not maintain that imprisonment alonecomprises Miranda custody. Nor does the testimonial in Maryland vs.Shartzer that “Nobody questions that the Shartzer the convict wasin detention for Miranda reasons” support a per se policy. Itmeans that just the problem of custody got no challenge in that case.Lastly, in contrast to the suggestion of the respondent, Miranda didnot hold the intrinsically persuasive pressures of custodialquestioning are present always when the convict is taken aside andinterrogated about the happening outside the prison (Harr & Hess,2002). The categorical rule of the Sixth Circuit- that detention,interrogation in private, and interrogation about the trial in theoutside world build a custodial condition for Miranda reasons- iswrong.
Harr,J. & Hess, K. (2002). Constitutionallaw and the criminal justice system (2nded.). Belmont, CA: Wadsworth/Thomson Learning.