(CN) – Rules for Miranda warnings may not apply to an inmate who was taken aside and questioned about events that occurred outside the prison walls, the U.S. Supreme Court ruled Tuesday.
Randall Fields claims he has a case for habeas relief under the Supreme Court’s landmark 1966 decision Miranda v. Arizona, which established that statements made during a police interrogation are not admissible in court unless a suspect has first been informed of his rights to remain silent and to consult a lawyer.
Fields was serving time in Michigan for disorderly conduct in 2001 when the Lenawee County Sheriff’s Department sough to question him about the alleged sexual abuse of a 12-year-old boy.
The five-to-seven-hour interrogation occurred in a conference room at the sheriff’s department where Fields was incarcerated. Sheriff’s deputies told Fields that he could return to his cell at any time, leaving the conference room door open at times and leaving Fields free of restraints. But they never gave Miranda warnings to Fields, and they never said he did not have to speak with the deputies.
Though Fields repeatedly stated during the interview that he did not want to talk to the deputies, he did not ask to go back to his cell and eventually confessed to masturbating the boy and engaging in oral sex with him on at least two occasions.
The state charged Fields with criminal sexual conduct, and the trial court refused to suppress his confession. Imprisoned for 10 to 15 years for the crimes, Fields exhausted the state appeals process but fared better when seeking federal habeas relief.
After a federal judge granted habeas relief, the 6th Circuit affirmed in 2010. Citing high court precedent, a three-judge panel said that the questioning situation to which Fields was subjected is always custodial.
In a summary order Tuesday, the U.S. Supreme Court disagreed that its decisions have clearly established this rule. The lower court’s categorical rule is “simply wrong,” according to the majority decision.
“On the contrary, we have repeatedly declined to adopt any categorical rule with respect to whether the questioning of a prison inmate is custodial,” Justice Samuel Alito wrote for the court.
Fields furthermore failed to prove that Miranda alone established the rule he seeks. “Miranda adopted a ‘set of prophylactic measures’ designed to ward off the “inherently compelling pressures” of custodial interrogation,’ but Miranda did not hold that such pressures are always present when a prisoner is taken aside and questioned about events outside the prison walls.,” Alito added. “Indeed, Miranda did not even establish that police questioning of a suspect at the station house is always custodial.”
“In sum, our decisions do not clearly establish that a prisoner is always in custody for purposes of Miranda whenever a prisoner is isolated from the general prison population and questioned about conduct outside the prison,” the opinion continues.
While Justice Ruth Bader Ginsberg agreed that the law is not clearly established in Fields’ favor, she said a direct review of the case should have precluded introduction of Fields’ confession at trial.
“I would not train, as the court does, on the question whether there can be custody within custody,” Ginsburg wrote. “Instead, I would ask, as Miranda put it, 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.’ Those should be the key questions, and to each I would answer ‘Yes.'”
Justices Stephen Breyer and Sonia Sotomayor joined in Ginsburg’s opinion.