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Howes v. Fields

United States Supreme Court
565 U.S. 499 (2012)


Facts

Randall Fields (defendant) was in prison when a corrections officer pulled him from his cell. The officer escorted him to a conference room where two sheriff’s deputies interrogated him for five to seven hours. The deputies told Fields several times he was free to leave and return to his cell if he did not want to cooperate but never gave him Miranda warnings. Fields eventually confessed to sex acts with a 12-year-old boy. After his conviction, Fields sought federal habeas relief on the ground that his confession was impermissibly obtained during custodial interrogation without Miranda warnings. The Sixth Circuit agreed, reasoning that interrogating a prisoner isolated from the general prison population and about events outside prison is always custodial. The United States Supreme Court granted review.

Rule of Law

Issue

Holding and Reasoning (Alito, J.)

Concurrence/Dissent (Ginsburg, J.)

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