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Name: Howes v. Fields
Case #: 10-680
Court: US Supreme Court
District USSup
Opinion Date: 02/21/2012
Subsequent History: 132 S.Ct. 1181; 182 L.Ed.2d 17

Police questioning of a prison inmate about misconduct occurring prior to incarceration, alone, does not constitute “custodial” for Miranda purposes. While serving a sentence in jail, Fields was questioned about alleged sexual conduct with a minor. He was not first advised of his Miranda rights. The lower court, advancing a categorical rule that (1) imprisonment, (2) questioning in private, and (3) questioning about events in the outside world created a “custodial” situation for Miranda purposes found a Miranda violation. For the following reasons, the Supreme Court ruled that this rule did not represent a correct interpretation of Miranda case law. (1) Under existing law, imprisonment alone is not enough to create a custodial situation for Miranda purposes. Rather, the imprisonment must be such that a reasonable person would not feel he was at liberty to terminate the interrogation and leave. (2) Questioning in private does not convert a non custodial situation to one requiring Miranda advisement. Quite the opposite–in the context of a jail setting, rather than removing a prisoner from a supportive atmosphere, a concern addressed by the Miranda court, questioning the inmate in private may serve to protect him from other inmates. (3) Finally, questioning about outside activities does not result in Miranda custody. Although the questioning may ultimately result in additional criminal liability, it would do so no more than questioning about criminal activity within the jail.