Thursday, January 31, 2013

Howes v. Fields case brief

Howes v. Fields case summary
132 S. Ct. 1181

The United States Court of Appeals for the Sixth Circuit affirmed the grant of habeas relief under 28 U.S.C.S. §2254(d)(1).
The court held that respondent inmate's interrogation was a "custodial interrogation" under Miranda because removal to a prison conference room and questioning about conduct that occurred outside the prison made any such interrogation custodial per se.
The petitioner, a warden, sought review and certiorari was granted.

  • The United States Supreme Court had expressly declined to adopt a per se rule. 
  • Standard prison conditions and restrictions did not necessarily implicate the same interests that Miranda sought to protect. 
  • Thus, being in prison, without more, was not enough to constitute Miranda custody. 
  • Taking the inmate to a conference room, as opposed to questioning him in the presence of fellow inmates, did not necessarily convert a noncustodial situation to one in which Miranda applied. 
  • Factors which leaned toward finding the inmate's questioning was custodial were offset by other factors.  For example, he was told at the outset, and reminded thereafter, that he could leave and go back to his cell whenever he wanted.  Also, he was not physically restrained or threatened and was not uncomfortable, was offered food and water, and the door to the conference room was sometimes left open. 
  • The objective facts were consistent with an interrogation environment in which a reasonable person would have felt free to terminate the interview and exit. 
  • Being told if he did not cooperate he would be returned to his cell was not coercion by threatening harsher conditions.

CONCLUSION: The judgment of the Sixth Circuit holding that the inmate was not in custody within the meaning of Miranda was reversed. 6-3 Decision; 1 opinion; 1 concurrence in part and dissent in part.

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