HOWES v. FIELDS

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Case Basics
Docket No. 
10-680
Petitioner 
Carol Howes, Warden
Respondent 
Randall Lee Fields
Decided By 
Advocates
(Solicitor General of Michigan, for the petitioner)
(Assistant to the Solicitor General, Department of Justice, for the United States, as amicus curiae, supporting the petitioner)
(for the respondent)
Term:
Facts of the Case 

A jury found Randall Fields guilty of two counts of third-degree criminal sexual conduct for the sexual abuse of a thirteen-year-old child. Fields was in jail on a disorderly charge when Lenawee County, Michigan deputies questioned him about allegations of sex with a minor. The sex case was unrelated to the one Fields was in jail for at the time.

Fields filed an appeal of right in the Michigan Court of Appeals claiming that his statements were inadmissible because he had not been given his Miranda warnings before questioning. The state court reasoned that because Fields was free to return to the jail and was questioned on a matter unrelated to his incarceration, there was no obligation to provide him warnings under Miranda.

Fields then filed a petition for a writ of habeas corpus under 28 U.S.C. § 2254 claiming that his Fifth Amendment right against self-incrimination was violated, and the U.S. District Court agreed. The United States Court of Appeals for the Sixth Circuit affirmed.

Question 

Does federal law automatically require Miranda warnings before questioning jail or prison inmates about issues unrelated to the cases for which they were incarcerated?

Conclusion 
Decision: 6 votes for Howes, 3 vote(s) against
Legal provision: Miranda warnings

Justice Samuel A. Alito, Jr. delivered the opinion of the Court reversing the lower court's decision. The Court stated that there was not yet any clearly established rule regarding what constituted Miranda custody. Mere imprisonment and private questioning about events in the outside world were not sufficient to create a custodial situation for Miranda purposes. Furthermore, the prisoner in this case was not in custody under Miranda because he was told at the outset of the interrogation that he could leave and go back to his cell whenever he wanted and because he was not physically restrained.

Justice Ruth Bader Ginsburg wrote an opinion concurring in part and dissenting in part, which Justice Stephen Breyer and Justice Sonia Sotomayor joined. Justice Ginsburg agreed that what constituted custody was not clearly established in Fields' favor. However, the justice disagreed with the Court's determination that Fields was not in custody because Fields was subjected to incommunicado interrogation in a police-dominated atmosphere, was placed in an inherently stressful situation against his will, and had his freedom of action curtailed in a significant way.

Cite this Page
HOWES v. FIELDS. The Oyez Project at IIT Chicago-Kent College of Law. 30 October 2014. <http://www.oyez.org/cases/2010-2019/2011/2011_10_680%20>.
HOWES v. FIELDS, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2010-2019/2011/2011_10_680%20 (last visited October 30, 2014).
"HOWES v. FIELDS," The Oyez Project at IIT Chicago-Kent College of Law, accessed October 30, 2014, http://www.oyez.org/cases/2010-2019/2011/2011_10_680%20.