Prison Interrogations

Miranda v. Arizona holds that to satisfy the Fifth Amendment’s privilege against self-incrimination and to counteract the inherent pressures of a custodial interrogation, a person undergoing such an interrogation by law enforcement personnel must be given specified warnings before the interrogation begins.

The U.S. Supreme Court’s recent decision in Howes v. Fields reversed the Sixth Circuit’s grant of habeas corpus relief to a defendant whose felony conviction was based largely on his non- Mirandized confession during a lengthy prison interrogation. Fields was serving a sentence for a disorderly persons offense when, at about 9 p.m., he was unexpectedly taken from his cell to a conference room within the prison, and interrogated for five to seven hours by armed sheriff’s officers. He was offered food and water but was not given his evening medications consisting of an antidepressant and antirejection medication needed because he had had a kidney transplant. The questioning continued even when he asked several times to terminate it and when he once became agitated, an armed deputy yelled at him using profanity and told him to sit down. Finally, at about 2 a.m., having confessed, he had to wait 20 minutes for a guard to escort him to his cell.