US Supreme Court rules prisoner’s interrogation didn’t violate ‘Miranda’

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A prisoner was not “in custody” for Miranda purposes when he was isolated from the general prison population and questioned about conduct that occurred outside the prison because he was informed he could leave when he wanted, was not physically restrained and the door to the room was sometimes open, the U.S. Supreme Court has ruled.

In the case, a man imprisoned for disorderly conduct was taken to a conference room and questioned by two deputies about his alleged sex abuse of a minor prior to his incarceration. Although he was told he could leave whenever he wanted, the defendant underwent seven hours of questioning before he confessed.

But when he was charged, the defendant argued that his jailhouse confession was inadmissible because he was never advised of his Miranda rights.

The 6th Circuit agreed, but the U.S. Supreme Court granted certiorari.

Writing for the majority, Justice Samuel Alito said that not all restraints on freedom of movement amount to custody for purposes of Miranda.

“[S]tandard 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,” the Court said.

Questioning a person who is already serving a prison term does not generally involve the shock that often accompanies arrest, a prisoner is less likely to be lured into speaking by a longing for prompt release and a prisoner knows that the officers questioning him probably lack the authority to affect the duration of his sentence, Justice Alito wrote.

Taking into account all of the circumstances of the questioning and emphasizing the fact the defendant was told he was free to end the questioning and return to his cell, the Court said that the defendant was not in custody within the meaning of Miranda.

Justice Ruth Bader Ginsburg authored a dissent which was joined by Justices Stephen Breyer and Sonia Sotomayor.

U.S. Supreme Court. Howes v. Fields, No. 10-690. Feb. 21, 2012.