Back to Basics: Police Officers Do Not Have to Mirandize Inmates in Jailhouse Interviews, Says SCOTUS

On Tuesday, February 21, 2012, the Supreme Court ruled in Homes v. Fields that police officers do not have to read the Miranda rights to inmates already incarcerated during jailhouse interviews for crimes unrelated to their incarceration.  Incidentally, the decision comes after the Court declined to establish a bright-line rule “for determining the applicability of Miranda in prisons,” the ruling it gave in Maryland v. Shatzer (2010).

In the 6-3 decision in Fields, it overruled the Sixth District Court of Appeals that had thrown out the child sex assault conviction of Randall Lee Fields due interrogating officers’  failure to read Fields his rights prior to interviewing him in a secluded interrogation room.  The Court stated that imprisonment per se does not create Miranda custody; that is, in determining whether a person is in custody under the Miranda case law, it is necessary to gauge whether in light of “objective circumstances of the interrogation” a “reasonable person would have felt he or she was not at liberty to terminate the interrogation and leave.”  (Such factors may include: the location of the questioning, the duration, the statements made during the interview, the presence of physical restraints, and the release of the interviewee at the end of the questioning.)

Here, Fields was serving a forty-five-day sentence in prison for disorderly conduct charges when he was removed from his cell and taken to a conference room to be questioned by sheriff’s deputies.  The deputies then questioned Fields for five hours regarding allegations of sexual assault on a minor.  Although Fields was told that he was free to leave at any time, Fields did not request to return to his cell and eventually confessed.  He was charged and convicted of criminal sexual assault.

Fields was sentenced to ten to fifteen years in prison but appealed on the basis of inadmissibility of his confessions, arguing that he was not properly Mirandized on the sexual assault charges.  Both the trial court and the Michigan Court of Appeals rejected Fields’ motion to suppress his confession.  The Supreme Court relied on two different approaches when ruling in Fields: (1) the Appeals Court’s erroneous granting of the writ of habeas corpus and (2) the application of a three-pronged test to determine whether the interrogation falls under Miranda custody.

The Court noted that writ of habeas corpus is proper in cases where the decision was contrary to clear and lawful holding of the Supreme Court.  As the Court went to great lengths to avoid establishing any bright-line rules on whether the questioning of a prison inmate is custodial, the Appeals Court relied on improperly interpreted case law in granting review as well as overturning the lower decision.  Further, the Supreme Court compared the environment and experience of a prisoner to that of a person not incarcerated when noting three distinguishing differences that would not give need to Mirandize an inmate.  First, questioning an inmate already serving a sentence is not similar to the shock of arrest experienced by a free person; second, an inmate is unlikely to be lured into speaking to the police by the idea of a release; and, third, the chance for a lightened sentence is unlikely for an inmate as he is already incarcerated.

Justice Alito, writing for the majority, emphasized that the facts of the case do not give rise to the presumption of Miranda custody.  While the duration of the interrogation may be viewed as excessive (Fields testified that it went on into the early morning, past his usual bedtime), Fields was told before the beginning of the interview and at various times during that he was free to leave at any time; in fact, at a certain point the deputy told him that if he did not wish to cooperate, he could go back to his cell.  Even though the deputies were armed, Fields was not physically restrained and the officers offered him food and water.  Justice Alito notes that since Fields was already in prison, the interrogation was not depriving him of any additional freedom; if he chose to leave the room, he would return to the same confines as he experienced prior – “under no circumstances could he have reasonably expected to be able to roam free.”

Justices Breyer and Sotomayor joined Justice Ginsburg in dissententing with the majority’s determination that Fields was not in custody under Miranda.  Justice Ginsburg emphasized that Miranda warning are required “in all settings in which a person’s freedom of action is curtailed in any significant way.”  Fields, while in custody for the purposes of serving his sentence, was not in custody under Miranda.  The “police-dominated atmosphere” that Fields was questioned in would be the main issue as opposed to the purposes of his incarceration.

The Fields decision, while not bright-line and all-inclusive, does serve a critical purpose in furthering interpreting the Miranda requirements.  It is common sense, and is noted by Justice Alito, that Fields was already serving a prison sentence and it cannot be overlooked that incarcerated individuals give up certain rights and privileges while in prison.  While that would not be an excuse to do away with all precautions rights against self-incrimination as guaranteed in the Fifth Amendment, a statement of “you are free to terminate this interrogation and return to your cell,” to an individual already experiencing a restriction in freedom of movement is not evident of constitutional violations.  If nothing else, it is a better definition for police officers to be aware of when conducting jailhouse interviews with inmates accused of other crimes.

Elena Gekker

Blogger, Criminal Law Brief

Image by Criminal Law Brief