Criminal Procedure — Miranda warnings — custody

U.S. Supreme Court

Criminal

Criminal Procedure — Miranda warnings — custody

There is no categorical rule that imprisonment, questioning in private, and questioning about events in the outside world create a custodial situation for Miranda purposes.

When a prisoner is questioned, the determination of custody should focus on all of the features of the interrogation. The record in this case reveals that respondent was not taken into custody for Miranda purposes. While some of the facts lend support to his argument that Miranda’s custody requirement was met, they are offset by others. Most important, he was told at the outset of the interrogation, and reminded thereafter, that he was free to leave and could goback to his cell whenever he wanted. Moreover, he was not physically restrained or threatened, was interviewed in a well-lit, averagesized conference room where the door was sometimes left open, and was offered food and water. These facts are consistent with an environment in which a reasonable person would have felt free to terminate the interview and leave, subject to the ordinary restraints of life behind bars.

617 F. 3d 813, reversed.

10-680 Howes v. Fields

Alito, J.; Ginsburg, J., concurring in part and dissenting in part.