Miranda for Prisoners

Miranda v. Arizona, the 1966 US Supreme Court case that is familiar to anyone who has ever seen a TV cop make an arrest, requires that police officers warn suspects who are “in custody” that they have a right to remain silent and to speak to an attorney. How the Miranda rule should apply to prison inmates, who are after all in custody 24/7, has been a thorn in many judges’ sides.

By a vote of 6-3, the Supreme Court removed some of the uncertainty with its decision in the case of Howes v. Fields (2012). The case makes it clear that prisoners are not necessarily “in custody” for purposes of Miranda simply because they are already confined when jailers pull them aside and question them about additional crimes they are suspected of committing.

Fields was serving time when a couple of sheriff’s officers took him to a prison conference room. Without advising Fields of his Miranda rights, the officers questioned Fields for 5 to 7 hours about allegations that he had sexually assaulted a young boy. Fields finally confessed, and the confession was used as evidence against him in his subsequent trial.

The Supreme Court ruled that Fields was not “in custody” for purposes of Miranda at the time of the interrogation. Thus the officers had no obligation to warn him that he had a right to remain silent and to consult with a lawyer. The majority emphasized that the officers told Fields a number of times that he could at any time stop the interrogation and return to his cell, that he was not handcuffed or otherwise physically restrained during the interrogation, and that he was offered food and water. Thus, under the “totality of the circumstances,” Fields was not in custody and his confession was properly admitted into evidence at trial.

The majority’s language is going to make it very difficult for prisoners to convince judges that they are in custody for purposes of Miranda when questioned by jailers. The majority mentioned that voluntary confessions are “an unmitigated good…essential to society’s compelling interest” in convicting criminals. The majority also stressed that unlike suspects who are plucked out of their houses or off the streets by police officers, prisoners know the ropes and aren’t shocked or pressured by isolation and questioning. So in addition to knowing the ropes, it’s up to prisoners to know about their Miranda rights.