Howes v. Fields

565 U.S. 499 (2012)

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Nature of the Case

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Facts

Fields (P) was escorted by a corrections officer to a conference room where two sheriff's deputies questioned him about allegations that, before he came to prison, he had engaged in sexual conduct with a 12-year-old boy. P was told that he was free to leave and return to his cell. Later, he was again told that he could leave whenever he wanted. The conference room was down a hall and through a locked door that separated two sections of the prison facility. P eventually confessed to engaging in sex acts with the boy. According to testimony at a suppression hearing, P said several times during the interview that he no longer wanted to talk to the deputies, but he did not ask to go back to his cell prior to the end of the interview. At no time was P given Miranda warnings or advised that he did not have to speak with the deputies. P was charged with criminal sexual conduct. P moved to suppress his confession, but the trial court denied his motion. P was convicted, and the Michigan Court of Appeals affirmed, rejecting P's contention that his statements should have been suppressed because he was subjected to custodial interrogation without a Miranda warning. The court ruled that P had not been in custody for purposes of Miranda during the interview, so no Miranda warnings were required. The court emphasized that P was told that he was free to leave and return to his cell but that he never asked to do so. The Michigan Supreme Court denied discretionary review. P filed a writ of habeas corpus, and the court granted relief. The Sixth Circuit affirmed, holding that the interview in the conference room was a “custodial interrogation” within the meaning of Miranda because isolation from the general prison population combined with questioning about conduct occurring outside the prison makes any such interrogation custodial per se. D appealed.