Howes v. Fields (2011)
- Docket
- 10-680
- Decided
- 2011-01-01
Summary
Question: Does federal law automatically require Miranda warnings before questioning jail or prison inmates about issues unrelated to the cases for which they were incarcerated? Conclusion: Justice Samuel A. Alito, Jr. delivered the opinion of the Court reversing the lower court's decision. The Court stated that there was not yet any clearly established rule regarding what constituted Miranda custody. Mere imprisonment and private questioning about events in the outside world were not sufficient to create a custodial situation for Miranda purposes. Furthermore, the prisoner in this case was not in custody under Miranda because he was told at the outset of the interrogation that he could leave and go back to his cell whenever he wanted and because he was not physically restrained. Justice Ruth Bader Ginsburg wrote an opinion concurring in part and dissenting in part, which Justice Stephen Breyer and Justice Sonia Sotomayor joined. Justice Ginsburg agreed that what constituted custody was not clearly established in Fields' favor. However, the justice disagreed with the Court's determination that Fields was not in custody because Fields was subjected to incommunicado interrogation in a police-dominated atmosphere, was placed in an inherently stressful situation against his will, and had his freedom of action curtailed in a significant way.