From the New York Times:
In a busy day at the , the justices on Tuesday issued a decision limiting the circumstances in which prisoners must be told of their rights before they are questioned…
Inmate Randall L. Fields confessed to a sex crime while being questioned by officers. He was not read Miranda rights, but he was not being held in custody as he was told that he had the freedom to leave.
The following are excerpts I’ve collected from the Howes v. Fields syllabus on the Supreme Court website.
From Page 3:
When a prisoner is questioned, the determination of custody should focus on all of the features of the interrogation. The record in this case reveals that respondent was not taken into custody for Miranda purposes. While some of the facts lend support to his argument that Miranda’s custody requirement was met, they are offset by others. Most important, he was told at the outset of the interrogation, and reminded thereafter, that he was free to leave and could goback to his cell whenever he wanted. Moreover, he was not physically restrained or threatened, was interviewed in a well-lit, averagesized conference room where the door was sometimes left open, and was offered food and water. These facts are consistent with an environment in which a reasonable person would have felt free to terminate the interview and leave, subject to the ordinary restraints of life behind bars.
From Page 4:
JUSTICE ALITO delivered the opinion of the Court.
The United States Court of Appeals for the Sixth Circuitheld that our precedents clearly establish that a prisoner is in custody within the meaning of Miranda v. Arizona, 384 U. S. 436 (1966), if the prisoner is taken aside and questioned about events that occurred outside the prisonwalls. Our decisions, however, do not clearly establishsuch a rule, and therefore the Court of Appeals erred inholding that this rule provides a permissible basis for federal habeas relief under the relevant provision of the Antiterrorism and Effective Death Penalty Act of 1996(AEDPA), 28 U. S. C. §2254(d)(1). Indeed, the rule applied by the court below does not represent a correct interpretation of our Miranda case law. We therefore reverse.
From Page 8:
Most recently, in Maryland v. Shatzer, 559 U. S. ___ (2010), we expressly declined to adopt a bright-line rule for determining the applicability of Miranda in prisons. Shatzer considered whether a break in custody ends the presumption of involuntariness established in Edwards v. Arizona, 451 U. S. 477 (1981), and, if so, whether a prisoner’s return to the general prison population after a custodial interrogation constitutes a break in Miranda custody. See 559 U. S., at ___ (slip op., at 3–4). In considering the latter question, we noted first that “[w]e have never decided whether incarceration constitutes custody for Miranda purposes, and have indeed explicitly declined to address the issue.” Id., at ___ (slip op., at 13) (citing Perkins, supra, at 299; emphasis added). The answer to this question, we noted, would “depen[d] upon whether [incar-ceration] exerts the coercive pressure that Miranda was designed to guard against—the ‘danger of coercion [that] results from the interaction of custody and official inter- rogation.’” 559 U. S., at ___ (slip op., at 13) (quoting Perkins, supra, at 297).
From Page 11:
Not only does the categorical rule applied below go wellbeyond anything that is clearly established in our prior decisions, it is simply wrong. The three elements of that rule—(1) imprisonment, (2) questioning in private, and (3) questioning about events in the outside world—are not necessarily enough to create a custodial situation for Miranda purposes.
As used in our Miranda case law, “custody” is a term ofart that specifies circumstances that are thought generallyto present a serious danger of coercion. In determining whether a person is in custody in this sense, the initial step is to ascertain whether, in light of “the objective cir- cumstances of the interrogation,” Stansbury v. California, 511 U. S. 318, 322–323, 325 (1994) (per curiam), a “reasonable person [would] have felt he or she was not at liberty to terminate the interrogation and leave.”
From Pages 16 and 17:
An inmate who is removed from the general prison population for questioning and is “thereafter … subjected to treatment” in connection with the interrogation “thatrenders him ‘in custody’ for practical purposes … will beentitled to the full panoply of protections prescribed by Miranda.” Berkemer, 468 U. S., at 440.
…
The record in this case reveals that respondent was not taken into custody for purposes of Miranda.
From Pages 20 and 22 respectively:
JUSTICE GINSBURG, with whom JUSTICE BREYER and JUSTICE SOTOMAYOR join, concurring in part and dissenting in part.
…
For the reasons stated, I would hold that the “incommunicado interrogation [of Fields] in a police-dominated atmosphere,” id., at 445, without informing him of his rights, dishonored the Fifth Amendment privilege Miranda was designed to safeguard.
From Page 1:
The trial court denied Fields’ motion to suppress his confessionunder Miranda v. Arizona, 384 U. S. 436, and he was convicted. The Michigan Court of Appeals affirmed, rejecting Fields’ contention thathis statements should have been suppressed because he was subjected to custodial interrogation without a Miranda warning.
To me, it does not sound like the ruling was incorrect. I understand Ginsburg, Breyer, and Sotomayor’s reasons for dissenting. If I was an inmate randomly taken to a room to be questioned by multiple officers, I would feel pretty helpless/powerless. Obviously it was a scare tactic being used by the officers. The fact of the matter is though that Fields was told that he was allowed to leave. If I was Fields, I would have just requested my lawyer to be present and let me go back to my cell in the meantime. Then again: I actually know my rights.