Howes v. Fields

Randall Lee Fields, in jail at the Lenawee County Sheriff’s Department for disorderly conduct, was taken into a locked conference room in the sheriff’s office sometime between 7 and 9 p.m. on December 23, 2001.  He was then questioned by two deputies for approximately seven hours.

Fields was not read his Miranda rights, but he was told he was free to go back to his cell whenever he wanted. Although he did not ask for an attorney or to go back to his cell, he repeatedly told the officers that he did not want to speak with them anymore.

By the end of the interview, Fields admitted to engaging in a number of sexual acts with then minor Travis Bice. Fields was ultimately convicted of two counts of third-degree criminal sexual conduct and was sentenced to a term of ten to fifteen years. His admissions during the interrogation were admitted in by the trial judge against his counsel’s objections.

The Michigan Court of Appeals affirmed the trial court, holding that Miranda warnings were not required because Fields was in custody on a matter unrelated to the interrogation and was told that he was free to leave.

Fields then petitioned for a writ of habeas corpus, which was granted by the district court and affirmed by the Sixth Circuit. The court found that the Michigan Court of Appeals’ decision directly contradicted the Supreme Court’s holding in Mathis v. United States, in which the Court found that a prisoner who was questioned by an IRS agent about the tax refunds he had claimed on his return must be read his Miranda rights.

Mathis was serving time in a state prison for an unrelated conviction at the time. The Sixth Circuit stated concisely: “The central holding of Mathis is that a Miranda warning is required whenever an incarcerated individual is isolated from the general prison population and interrogated, i.e. questioned in a manner likely to lead to self-incrimination, about conduct occurring outside of the prison.”

In oral arguments on October fourth, counsel for the petitioner focused on two overarching factors that the government argued should lead the Court to determine that a reasonable person in Fields shoes would feel that he was free to return to his cell: the fact that he was repeatedly told he could go back to his cell and that the officers honored his request to leave when he made one.

Justice Sotomayor pushed the petitioner’s argument, questioning why the fact that officers continued questioning Fields for twenty minutes after he asked to leave and the fact that Fields stated he didn’t want to speak with them didn’t overcome petitioner’s factors. Counsel for the petitioner responded that it was his choice to continue to talk after he said he didn’t want to anymore and the twenty minute delay in taking him away is consistent with prison procedures.

In his brief, Respondent Fields argues that “[t]he Sixth Circuit’s bright-line approach rests on well-established constitutional principles already identified by” the Supreme Court and “[t]hat no circuit, other than the Sixth Circuit, has used a bright-line approach is not decisive where it was the only one to be presented with a fact situation identical to the one found in Mathis.”

Fields also defends Miranda principles, as laid down by the Court’s past precedent. More broadly, he argues that the Fifth Amendment privilege “will continue to be protected by, and law enforcement and the judiciary will benefit from, a bright-line approach to the question of when a prisoner is in interrogative custody.”

The Respondent argues that the appropriate place to draw a bright-line rule is at “[i]solation from the general prison population and questioning by officers unaffiliated with the facility about conduct occurring outside the prison.” Fields also supports rule by claiming that it “does not confer greater rights on the imprisoned than it does on the unimprisoned, nor does it conflict with administrative concerns within the prison[,]” and by arguing generally that “[s]ociety’s need for interrogation does not outweigh the Fifth Amendment privilege.