Howes v. Fields, No. 10-680; U.S. Supreme Court; opinion by Alito, J.; partial dissent by Ginsburg, J.; decided February 21, 2012. On certiorari to the U.S. Court of Appeals for the Sixth Circuit.
Respondent Fields, a Michigan state prisoner, was escorted from his prison cell by a corrections officer to a conference room, where he was questioned by two sheriff’s deputies about criminal activity he had allegedly engaged in before coming to prison. At no time was Fields given Miranda warnings or advised that he did not have to speak with the deputies. As relevant here: Fields was questioned for between five and seven hours; Fields was told more than once that he was free to leave and return to his cell; the deputies were armed, but Fields remained free of restraints; the conference room door was sometimes open and sometimes shut; several times during the interview Fields stated that he no longer wanted to talk to the deputies, but he did not ask to go back to his cell; after Fields confessed and the interview concluded, he had to wait an additional 20 minutes for an escort and returned to his cell well after the hour when he generally retired. The trial court denied Fields’ motion to suppress his confession under Miranda v. Arizona , 384 U.S. 436, and he was convicted.
