February 23, 2012
If one of the most recent Supreme Court rulings is any indication, the current Court isn’t a big fan of inmate rights. Or Miranda rights, for that matter.
Howes v. Fields, a decision handed down by the Court on Tuesday, involved Michigan inmate Randall Fields, who was serving time for disorderly conduct.
At about 8:00 p.m. one night, Fields 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.
Fields was questioned for between five and seven hours.
At the beginning of the interview and on at least one occasion later in the interview, Fields was told that he was free to leave and return to his cell.
After some heated arguments, he eventually confessed to engaging in sex acts with the boy.
Fields was convicted and sentenced to a term of 10 to 15 years of imprisonment.
On appeal, Fields sought suppression of his confession, arguing that it was improperly obtained under a custodial interrogation without a Miranda warning.
After a series of appeals, it reached the Supreme Court, who ruled 6-3 against Fields.
Well, actually the Court unanimously ruled to reverse the appeals court on the grounds that the precedent it cited to rule for Fields was incorrect.
All of the Justices agreed further that there was no precedent squarely on point for this matter – that is, whether a prisoner who is interrogated away from the rest of the prison population about events that occurred outside of the prison constitutes “custody” for Miranda purposes.
The six Justice majority, though, saw this as an opportunity to create a new rule that honestly only serves to weaken Miranda rights.
Specifically, the Fields ruling established that “imprisonment alone is not enough to create a custodial situation within the meaning of Miranda.”
The Court rested this proposition on three grounds.
First, questioning a person who is already serving a prison term does not generally involve the shock that very often accompanies arrest.
Second, a prisoner is unlikely to be lured into speaking by the temptation for prompt release (how any reasonable person could ever believe that making self-incriminating statements could lead to a faster release eludes me).
Third, a prisoner knows that the law enforcement officers who question him probably lack the authority to affect the duration of his sentence.
Taken together, the majority said, these three factors remove the element of coercion that is necessary for Mirandacustody scenarios.
Hot Doc: Howes v. Fields
Regardless of the majority’s logic (or lack thereof) on this point, the heart of the majority’s ruling rested on the assertion that Fields was told multiple times throughout the interrogation that he was free to leave anytime he wished.
At least the majority’s reasoning here stayed a bit truer to the Miranda ruling, which holds that Miranda warnings are required “in all settings in which [a person's] freedom of action is curtailed in any significant way.”
This is the main point of divergence for the Court.
The dissent instead found irrelevant the question of “whether there can be custody within custody” (on which the majority was so affixed).
Instead, the dissent would ask, whether Fields was subjected to “incommunicado interrogation … in a police-dominated atmosphere,” whether he was placed, against his will, in an inherently stressful situation, and whether his “freedom of action [was] curtailed in any significant way.”
The dissent, of course, answered “yes” to all of these questions (otherwise they wouldn’t have dissented).
And its conclusion is far more logical than the majority’s on this point.
Yes, Fields was indeed told on more than one occasion during the middle-of-the-night interrogation that he was free to leave anytime he wished.
But he was in prison. And not the minimum security, white-collar resort prisons the majority likely had in mind in making its ruling.
When you’re in prison, you do what the guys with the guns want you to do.
In fact, Fields himself believed the deputies “would not have allowed [him] to leave the room.”
Furthermore, more than once, “he told the officers … he did not want to speak with them anymore.”
Granted, Fields could just have been saying this after the fact in an effort to suppress the confession.
But how likely is it really that a prison inmate would voluntarily stay up well into the early morning hours discussing with law enforcement officers his criminal behavior that he hadn’t been prosecuted for?
How likely is it that Fields would have voluntarily confessed to sexually molesting a 12-year-old when he was only in prison for disorderly conduct?
Thanks to the Court’s ruling, though, the answers to those questions are irrelevant.
As long as a prison inmate is told that he is free to leave, regardless of whether such an assertion is made truthfully, no Miranda rights attach.
So, to all of you inmates out there reading this: the Supreme Court is letting you know that you shouldn’t count on having any Miranda rights, so your safest bet is to keep your mouth shut at all times.