Supreme Court declines to expand definition of custodial for Miranda purposes

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Supreme Court declines to expand definition of custodial for Miranda purposes

February 21, 2012 01:21:52 pm

[JURIST] The US Supreme Court [official website] ruled 6-3 [opinion, PDF] Tuesday in Howes v. Fields [SCOTUSblog backgrounder] that a US Court of Appeals for the Sixth Circuit categorical rule that all private questioning of prisoners about outside events is per se custodial, requiring Miranda warnings to be given, is not clearly established by Supreme Court precedent. The court also declined to establish a rule that interrogations are per se custodial for the purposes of Miranda, when a prisoner is questioned in private about events occurring outside the prison. Respondent Randall Fields was questioned by investigators about a child sex-abuse case while he was in the county jail serving a 45-day sentence for disorderly conduct. A lower court found that Fields did not have to be given his Miranda rights because the investigators were questioning him about a separate crime. This decision was reversed [opinion] by the Sixth Circuit, holding that Miranda is necessary anytime the suspect is isolated from the rest of the jail inmates in a situation where the suspect would be likely to incriminate himself. In an opinion delivered by Justice Samuel Alito, the Supreme Court reversed:

In short, standard conditions of confinement and associated restrictions on freedom will not necessarily implicate the same interests that the Court sought to protect when it afforded special safeguards to persons subjected to custodial interrogation. Thus, service of a term of imprisonment, without more, is not enough to constitute Miranda custody.

The court further stated that the determination of custody should focus on all features of the interrogation including the manner and language summoning the prisoner to the questioning and the manner in which the interrogation occurs. Justice Ruth Bader Ginsburg filed an opinion concurring with the majority as to whether Supreme Court precedent clearly establishes a categorical rule for what constitutes custody but dissented on the issue of whether Fields was in custody for Miranda purposes. Ginsburg was joined in her opinion by Justices Stephen Breyer and Sonia Sotomayor.

During oral arguments, attorneys representing the state of Michigan argued [JURIST report] that since Fields invoked his right to return to his cell, despite being confined in jail, a reasonable person in jail being taken to an interrogation room would have understood it was an interrogation and Miranda was unnecessary. They further argued against the per se rule that was created by the Sixth Circuit rather than applying the traditional “all the circumstances” test for Miranda. Fields’ attorney contended that he felt no freedom to leave and that in a prison or jail situation, a reasonable person would not feel a freedom to leave without being read Miranda rights in that situation.

Martin Luther King Jr. wrote his Letter from Birmingham Jail

On April 16, 1963, an incarcerated Martin Luther King, Jr. (arrested for demonstrating in defiance of a court order) wrote his Letter from Birmingham Jail in response to a published statement by eight fellow clergymen from Alabama.

Part of the letter read: We have waited for more than 340 years for our constitutional and God-given rights. The nations of Asia and Africa are moving with jetlike speed toward gaining political independence, but we stiff creep at horse-and-buggy pace toward gaining a cup of coffee at a lunch counter. Perhaps it is easy for those who have never felt the stinging dark of segregation to say, "Wait." But when you have seen vicious mobs lynch your mothers and fathers at will and drown your sisters and brothers at whim; when you have seen hate-filled policemen curse, kick and even kill your black brothers and sisters; when you see the vast majority of your twenty million Negro brothers smothering in an airtight cage of poverty in the midst of an affluent society; when you suddenly find your tongue twisted and your speech stammering as you seek to explain to your six-year-old daughter why she can't go to the public amusement park that has just been advertised on television, and see tears welling up in her eyes when she is told that Funtown is closed to colored children, and see ominous clouds of inferiority beginning to form in her little mental sky, and see her beginning to distort her personality by developing an unconscious bitterness toward white people; when you have to concoct an answer for a five-year-old son who is asking: "Daddy, why do white people treat colored people so mean?"; when you take a cross-county drive and find it necessary to sleep night after night in the uncomfortable corners of your automobile because no motel will accept you; when you are humiliated day in and day out by nagging signs reading "white" and "colored"; when your first name becomes "nigger," your middle name becomes "boy" (however old you are) and your last name becomes "John," and your wife and mother are never given the respected title "Mrs."; when you are harried by day and haunted by night by the fact that you are a Negro, living constantly at tiptoe stance, never quite knowing what to expect next, and are plagued with inner fears and outer resentments; when you are forever fighting a degenerating sense of "nobodiness" then you will understand why we find it difficult to wait. There comes a time when the cup of endurance runs over, and men are no longer willing to be plunged into the abyss of despair. I hope, sirs, you can understand our legitimate and unavoidable impatience. Read the full text of the Letter.